**Status Report to the Court**

**Number Twenty-Two**

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**For the Period**

**April 1, 2005 through June 30, 2005**

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**August 1, 2005**

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**TABLE OF CONTENTS**

[**I.** **INTRODUCTION** 3](#__RefHeading___Toc110653573)

[**II.** **SECRETARY GALE NORTON'S OBSERVATONS**
4](#__RefHeading___Toc110653574)

[**A.** **INFORMATION TECHNOLOGY** 6](#__RefHeading___Toc110653575)

[**B.** **CADASTRAL SURVEY** 15](#__RefHeading___Toc110653576)

[**C.** **MINERALS MANAGEMENT SERVICE**
18](#__RefHeading___Toc110653577)

[**D.** **OFFICE OF HISTORICAL TRUST ACCOUNTING**
19](#__RefHeading___Toc110653578)

[**III.** **OFFICE OF THE SPECIAL TRUSTEE FOR AMERICAN INDIANS**
29](#__RefHeading___Toc110653579)

[**A.** **TRUST REVIEW AND AUDIT** 32](#__RefHeading___Toc110653580)

[**B.** **OST-OFFICE OF THE CHIEF INFORMATION OFFICER**
34](#__RefHeading___Toc110653581)

[**1.** **RECORDS MANAGEMENT** 34](#__RefHeading___Toc110653582)

[**C.** **TRUST ACCOUNTABILITY** 37](#__RefHeading___Toc110653583)

[**1.** **TRUST BUSINESS PROCESS MODELING**
37](#__RefHeading___Toc110653584)

[**2.** **TRUST DATA QUALITY AND INTEGRITY**
40](#__RefHeading___Toc110653585)

[**3.** **INDIAN FIDUCIARY TRUST TRAINING PROGRAM**
43](#__RefHeading___Toc110653586)

[**4.** **RISK MANAGEMENT** 45](#__RefHeading___Toc110653587)

[**5.** **REGULATIONS, POLICIES AND PROCEDURES**
47](#__RefHeading___Toc110653588)

[**D.** **FIELD OPERATONS** 49](#__RefHeading___Toc110653589)

[**1.** **APPRAISAL** 49](#__RefHeading___Toc110653590)

[**E.** **TRUST SERVICES** 52](#__RefHeading___Toc110653591)

[**1.** **CURRENT ACCOUNTING ACTIVITIES**
52](#__RefHeading___Toc110653592)

[**IV.** **BUREAU OF INDIAN AFFAIRS** 57](#__RefHeading___Toc110653593)

[**A.** **TRUST REGULATIONS, POLICIES AND PROCEDURES**
57](#__RefHeading___Toc110653594)

[**B.** **FRACTIONATION** 59](#__RefHeading___Toc110653595)

[**C.** **PROBATE** 61](#__RefHeading___Toc110653596)

[**ACRONYMS AND ABBREVIATIONS** 63](#__RefHeading___Toc110653597)

I.  []{#__RefHeading___Toc110653573 .anchor}**INTRODUCTION**

This *Status Report to the Court Number Twenty-Two* (Report) represents
the period from

April 1, 2005, through June 30, 2005. The Report is presented for the
purpose of informing the Court on the progress of trust reform
activities occurring during this reporting period, and 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. Each manager in charge of an area of trust administration and
the director of the historical accounting project are submitting reports
on the progress of their respective activities.

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

II. []{#__RefHeading___Toc110653574 .anchor}**SECRETARY GALE NORTON'S
    OBSERVATONS**

I continue to be deeply impressed with the dedicated efforts of the many
Interior employees, most of whom are American Indians, who are working
to ensure that Interior's fiduciary trust responsibilities are met. Our
management team, headed by Jim Cason and Ross Swimmer, has worked hard
to improve the organization and professionalism of our trust activities,
as well as our other Indian responsibilities. They are making methodical
progress on issues that have been ignored for decades. My own experience
with Interior's employees and the work they do simply cannot be
reconciled with the disparaging remarks made by the Court in its July 12
opinion.

Of course, I am also constantly reminded of the difficulties we face in
transforming a century-old system into a modern, beneficiary-centered
financial services organization. At the cutting edge of this transition
is the implementation of the Fiduciary Trust Model at the pilot agencies
of Concho and Anadarko. Their work includes the conversion of data from
key legacy computer systems to new systems that eventually will be
installed at all BIA agencies. As a result of interfacing software
components of TAAMS leasing and title with TFAS, we will be able to
provide comprehensive asset statements to beneficiaries served by these
two agencies. The Office of Special Trustee expects these statements to
be sent to beneficiaries during the next reporting period.

Lessons learned from implementing the FTM at these locations will help
significantly as we move forward to other BIA agencies. Although
considerable work will be necessary to implement changes at each agency
in the future, this progress at the pilot agencies is a major
accomplishment toward reform of the Indian trust.

Another important step in trust reform is implementation of the American
Indian Probate Reform Act. The Act's notice requirement was satisfied
during this reporting period. On June 20, 2005, I certified that the
notice provisions had been met through mailings and publication. As a
result, certain provisions in the Act will become effective in one year.
During this year, training will continue for Interior staff, and
beneficiaries will have an opportunity to become familiar with the
various probate changes that might affect them.

As part of the implementation of trust improvements, we began an
Interior Regulatory Initiative during this reporting period. To the best
of my knowledge, this is the most comprehensive updating of
trust-related regulations in decades. The Regulatory Initiative brings
together multi-agency working groups consisting of employees from BIA,
OST, BLM, NBC, SOL, OHA and OHTA. Instead of the traditional slow
process of writing individual regulations and then circulating them
through the Department for incremental editing, the groups have been
brainstorming about necessary changes, using their varied expertise to
identify improvements, and working together to create drafts. The
working groups are developing regulations that further the FTM, comply
with requirements of the new probate act, and streamline other business
processes. Some of the draft regulations are expected to be presented
for consultation by the end of the calendar year.

With the recent introduction by Senators McCain and Dorgan of a bill,
S.1439, to settle the accounting claims in the *Cobell* litigation, I
think it is appropriate to summarize the substantial progress the
Department has made since 2001 in performing the historical accounting.
This progress has been made in spite of the fact that Congress continues
to appropriate significantly less for accounting work than the
Administration requests. For FY2006, for example, the Senate and House
passed versions of the Interior appropriations bill that each propose to
give the Department only \$58 million of the \$135 million it requested.

I have been informed that, as of June 30, 2005, the Office of Historical
Trust Accounting had fully reconciled 52,165 of the 99,572 judgment and
per capita accounts (including some with no current balance). Statements
detailing the results of the accounting have been mailed to 12,122
account holders, and OHTA is awaiting permission from the court to send
the results to an additional 28,107 account holders.

From OHTA's description of the accounting results to date, there do not
appear to be any systemic accounting issues or bias in the accounting
results. Differences between accounting ledgers and supporting
documentation sometimes favor account holders and sometimes disadvantage
them. In other words, the dollar differences go both ways. The
differences found do not seem to indicate fraud, theft, or
misapplication of accounting rules. Rather, the differences appear to be
random computational, posting, or distribution errors.

The accounting and trust reform efforts continue in the midst of
significant litigation-related demands on the Department's time and
resources. As I write this, the Court's hearing on IT security at the
Department is drawing to a close. I understand that, since April 26,
Interior has produced over 4.5 million pages of documents for the
hearing and nearly 20 employees have provided testimony. While the
hearing is meant to assess vulnerabilities in the security measures that
the Department has taken to protect the Indian trust data that it stores
electronically, I am concerned that the litigation itself, in which
detailed information on those security measures is being made available
to the public, may present the greatest vulnerability that the
Department faces in the area of IT security.

In the past few days, Interior has also devoted considerable high-level
attention to this Court's recent order that Interior put a notice in
every written communication that Interior sends to present and former
IIM account holders. We are concerned this will be a huge task that will
impose ongoing requirements on potentially thousands of employees for an
indefinite period and that will negatively impact Interior's
relationship with Indian beneficiaries.

As mentioned earlier, legislation has been introduced in Congress to
address individual Indian trust claims. I look forward to the
opportunity to work with Congress on this issue. I hope that this
legislation will finally address longstanding issues that have been
unresolved for decades, and allow both Interior and Indian Country to
focus on the future.

A.  []{#__RefHeading___Toc110653575 .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:**

Interior continues to make progress in ensuring IT security and, in
particular, addressing the potential risks associated with unauthorized
access to IITD from the Internet. A primary focus for this reporting
period has been providing documentation responsive to the April 25,
2005, Court Order. Over 4.5 million pages of documentation have been
collected and produced pursuant to this Order. Additional efforts were
focused on responding to penetration test results from our contracted
monitoring program through the Inspector General, preparing for the
annual FISMA evaluation, completing site and facility compliance
reviews, conducting annual IT security awareness training, and
continuing to validate and improve the C&A packages completed
previously. The most noteworthy accomplishments and completions during
the reporting period are described below.

***Prevention and Monitoring***

-   Interior continued testing Internet-accessible systems against an
    operational security profile based on the SANS Top 20 vulnerability
    list. For the fifth consecutive reporting period, no hosts were
    found to have vulnerabilities listed in the SANS Top 20. The SANS
    Top 20 lists the ten most commonly exploited vulnerabilities in
    Windows, and the ten most commonly exploited vulnerabilities in
    Unix. Although there are thousands of security incidents each year
    affecting these operating systems, the overwhelming majority of
    successful attacks target one or more of these twenty services.
    These monthly scans assist bureaus and offices in prioritizing their
    IT security efforts so they can address the most dangerous network
    vulnerabilities first.

-   Interior initiated more robust automated vulnerability scan testing
    of Internet-accessible systems to include more than the SANS Top 20
    vulnerability listing. Potential vulnerabilities were detected and
    are being analyzed or have been mitigated. Results from these
    heightened scanning activities are expected to be reflected in
    future reports as Interior further refines the process.

-   Potential incidents that were reported to DOI-CIRC during this
    reporting period, are as follows:

  ----------------------- ------------------------ ----------------------
  **Type of Incident**    **Number Unsuccessful**  **Number Successful**

  Intrusion               0                        0

  DoS/DDoS                1                        0

  Virus/Malicious Code    835,251                  10

  System Misuse           61,547                   4

  Social Engineering      161                      0

  Web Defacement          0                        0

  Root Compromise         7                        0

  User Compromise         0                        0

  Hoax                    0                        0

  Scanning/Probes         307,515,988              10

  Trojan/Backdoor         10                       0

  Other (Incidents N/A to 45,455,606               9
  above categories)                                

  ***Total***             **353,868,575**          **33**
  ----------------------- ------------------------ ----------------------

-   The types of incidents reported in the "Other" category include any
    type of potential incident not included in the other areas. Examples
    of those incidents include: laptop theft, e-mail address spoofing
    and spam/fraudulent e-mail received. Of the 33 reported successful
    incidents occurring during this reporting period, none appear to
    have resulted in any known compromise of sensitive data. Successful
    incidents are those that could not be prevented or blocked by
    Interior at the time of their occurrence.

-   In the previous reporting period, BLM received initial results from
    the contracted penetration testing. The IG's contractors reported
    successful penetration of BLM's external perimeter and Intranet
    servers. The contractor also noted the presence of up-to-date
    patches on servers, and external DNS servers were identified as
    being compliant with best security practices. Two IITD servers
    responded to a ping test. However, the contractors did not report
    exploit of servers containing IITD. Attempts to exploit IITD would
    have met additional layers of security controls. These include
    password protection on the underlying databases, application-level
    security implemented via internally defined access control lists and
    implementation of strong passwords on BLM's Indian trust software
    application user accounts.

> After the contractor penetration testing, BLM took immediate action to
> further increase its IT security. BLM implemented the recommendations
> made in the IG penetration report and, as a result, has significantly
> strengthened BLM's overall IT security architecture. BLM first
> responded to the initial results by taking immediate steps to further
> protect IITD by disconnecting trust servers and workstations from the
> BLM network. There has been a long-standing issue in BLM concerning
> the need to segregate these servers into a virtual private network.
> These servers are not expected to be reconnected until the
> segmentation is completed. BLM implemented corrective actions for the
> technical vulnerabilities identified by the IG. These actions have
> improved the level of BLM's network security. BLM has also joined the
> Departmental WAN (ESN), which provides another layer of network
> security. BLM has slowly been restoring Internet services after
> thorough testing and verification of security improvements, and
> expects to continue to implement longer-term solutions that prevent
> and detect vulnerabilities.

-   NBC received initial results from the contracted penetration testing
    initiated in the last reporting period. The IG's contractor that
    performed the NBC penetration testing was able to access some of the
    components of the NBC systems. During the testing, the IG contractor
    did not access any NBC-hosted IITD applications. These applications
    are isolated and protected; penetration into that portion did not
    occur.

> The IG's contractor did successfully penetrate a reporting database
> allowing viewing of confidential personnel information pertaining to
> Interior employees and employees in other agencies using Interior
> financial services. NBC has initiated an extensive remediation plan to
> address vulnerabilities identified in the penetration testing against
> NBC systems. Immediate action was taken to resolve or mitigate
> critical vulnerabilities. During this reporting period, 21 of 37
> identified remediation tasks have been completed, and NBC continues to
> track progress of remaining tasks.
>
> As part of the remediation effort, NBC purchased additional tools to
> identify web application and database vulnerabilities. Using one of
> those tools, approximately 50 critical web applications have gone
> through an initial vulnerability scan and remediation effort, and are
> being rescanned. NBC has also begun initial database vulnerability
> scans and analysis.

-   During this reporting period, the IG's contractor conducted
    extensive penetration testing against MMS systems, but was unable to
    access its systems or data.

-   OST upgraded its intrusion detection sensors, which enhanced its
    network monitoring capability by allowing more of its network to be
    monitored.

-   OHA completed the migration of its network operating systems to
    Interior's Active Directory, providing a single operating directory
    for control of user access to network resources.

***Policies and Guidance***

-   The Interior CIO issued OCIO Directive 2005-007, "FY 2005 Plans of
    Action and Milestones (POA&M) Process Verification," to the heads of
    bureaus and offices on May 3, 2005. This directive establishes
    criteria for maintaining, improving and certifying the POA&M
    process.

-   The Interior CIO issued a memorandum, "Enterprise Services Network
    (ESN) Connection Approval Process," to the bureau and office chief
    information officers on May 24, 2005. This memorandum establishes a
    connection approval process for creating a single WAN by joining
    bureau WANs. BLM was the first bureau to complete the process and
    join the Department's WAN (ESN).

***Training and Awareness***

-   Interior completed annual IT security awareness training for over
    92% of Interior staff as of the end of this reporting period.

-   Interior entered into an agreement with OPM to provide online
    training as a means to deliver role-based IT security training for
    bureaus and offices subscribing to this service.

-   The quarterly MMS Information Security Awareness Newsletter, Spring
    2005, was distributed to employees and contractors to keep users
    abreast of IT security issues.

**Plans of Action and Milestones:**

Interior tracked 1,659 POA&M recorded weaknesses, of which 521
weaknesses were identified this quarter and 1,138 weaknesses were
carried over from the second quarter. Interior remediated and closed out
453 weaknesses this quarter. Interior is currently tracking 1,206 open
weaknesses.

**A-130 Certification and Accreditation:**

During this reporting period, 42 non-trust and 2 trust C&A packages were
independently reviewed by a contractor. In addition, C&A packages that
had not met minimum compliance review scores on initial reviews continue
to be improved.

**IT Systems Architecture:**

Interior's enterprise architecture program was rated the highest among
25 federal agencies assessed by OMB. DOI's EA program received a 4.06
rating, with the average rating among federal agencies being a 3.19.
This rating signifies the architecture is being operationalized across
Interior and is providing performance impact to business operations.
This is consistent with Interior's previously-reported self-assessment.
Interior's top-rated IT architecture program greatly adds to Interior's
position that we are adequately securing our IT systems and data.

The "Department of the Interior Transition Plan" was developed, reviewed
and submitted to OMB for assessment. This document provides a structured
approach for closing the gap between Interior's current or "as-is"
architecture and its conceptual target architecture. This approach is
supported by a structured methodology and supporting tools (e.g., DEAR),
which are used to improve Interior's mission performance.

Approximately 63% of Interior's systems inventory contained in DEAR has
been mapped to the BRM. During this reporting period, Interior launched
a Department-wide effort for mapping its systems inventory contained in
DEAR to the DRM. The DRM contains high-level categories of data managed
by DOI (e.g., recreation, financial, etc.). This information is useful
in determining potential authoritative data sources in Interior's system
portfolio. At the time of this report, approximately 68% of the systems
contained in DEAR have been mapped to the DRM. As noted in the last
Status Report to the Court, Interior continues to validate Phase 3B
populated data and make appropriate updates and corrections as needed.

***DOI Land and Resource Management System (DLRM)***

As previously reported, the DLRM system is expected to provide a
long-term solution for the legacy functionality of the CGI leasing
software module, formerly a part of the TAAMS project.

The FRD for DLRM was approved, which is expected to enable the DLRM to
replace certain legacy systems and interface with other systems as
required. The acquisition phase of the project began with the assignment
of a contracting officer and the solicitation is expected to be
published in August 2005.

The UAT for Version 2.0 of the realty (leasing) portion of TAAMS was
conducted through April 1, 2005. The tests covered range, forestry,
surface, minerals, rights-of-way, and leasing reports. The tests were
successful for all of the areas, and it was determined that the reports
are suitable for use but may need more modification. Use of TAAMS as an
interim solution for leasing was approved by the TESC. The TAAMS pilot
went "live" at the Anadarko and Concho agencies on June 30, 2005.

**ESN**

-   The ESN was certified and accredited on April 15, 2005.

-   Five ESN Internet gateways were installed. These gateways are
    expected to provide consolidated Internet service to the Department
    with additional layers of perimeter security.

-   On June 28, 2005, BLM became the first bureau to be connected to the
    ESN.

**ZANTAZ**

-   As noted in the previous reporting period, OSM had discovered an
    additional transmission problem in March. This was determined to be
    a problem involving a Dynamic Linking Library file installed on 53
    workstations. The problem lasted from March 7 through March 23.
    Affected messages were retransmitted to ZANTAZ on April 5 and 6.
    From April 5 through April 10, there was a disruption in OSM's VPN
    to ZANTAZ, which delayed transmission of messages to ZANTAZ. OSM
    experienced similar problems for the periods of May 14 through May
    19 and from May 30 through June 2, again delaying the transmission
    of messages to ZANTAZ. During this reporting period, OSM migrated
    from GroupWise to Outlook in order to resolve these transmission
    problems.

-   As noted in the previous reporting period, NBC's e-mail messages
    likely did not travel to the ZANTAZ Digital Safe on February
    15-17, 2005. NBC sent three back-up tapes containing e-mail messages
    captured during that time period to ZANTAZ. The NBC tapes have been
    processed and messages successfully restored.

-   As reported in open court on June 30, 2005, NBC discovered on June
    21, 2005, that some of its e-mail servers were not transmitting all
    e-mail messages to the ZANTAZ Digital Safe. NBC expects to correct
    the issue during the next reporting period. Other bureaus and
    offices that transmit e-mail messages to the Digital Safe are being
    tested for similar issues. As reported in open court on July 17,
    2005, so far, only SOL and BIA report similar problems.

-   Though these systems do not house or access IITD, NBC wishes the
    Court to be aware of two matters involving its Boise and Reston
    offices: (1) Prior to March 1, 2005, Boise did not retain backup
    tapes indefinitely; (2) Prior to October 30, 2004, Reston did not
    retain backup tapes indefinitely.

-   On May 13 and 17, 2005, due to a BLM server outage, BLM was unable
    to send e-mail messages to the ZANTAZ Digital Safe. In both cases,
    after BLM resolved the issue, messages queued during these incidents
    went to ZANTAZ. []{.mark}

**A-130 Certification and Accreditation:**

-   Ninety-seven percent of Interior systems have full authority to
    operate (ATO) status. C&A reviews conducted by a qualified third
    party have been completed for 67% of the C&A packages as of the end
    of this reporting period. 67% of these packages received passing
    scores.

-   43 systems were identified as responsive to the current evidentiary
    hearing. Of these, 34 have received passing scores and nine are
    pending initial or second review.

**Reports:**

These reports may be of interest to the Court.

-   GAO issued "Internet Protocol Version 6: Federal Agencies Need to
    Plan for Transition and Manage Security Risks" (GAO 05-471) and
    "Internet Protocol Version 6: Federal Agencies Need to Plan for
    Transition and Manage Security Risks" (GAO-05-845T). These reports
    cover issues regarding emerging technology issues government-wide.

-   GAO issued "Information Security: Federal Agencies Need to Improve
    Controls over Wireless Networks" (GAO-05-383). This report assesses
    the status of wireless networks generally.

-   GAO issued "Information Security: Emerging Cybersecurity Issues
    Threaten Federal Information Systems" (GAO-05-231). This report
    assesses the challenges from new IT security threats
    government-wide.

-   GAO issued "Information Security: Improving Oversight of Access to
    Federal Systems and Data by Contractors Can Reduce Risk"
    (GAO-05-362). This report assesses risks and responses to contractor
    access to IT systems and data government-wide.

-   GAO issued "Information Security: Continued Efforts Needed to
    Sustain Progress in Implementing Statutory Requirements"
    (GAO-05-483T). This report addresses implementation of FISMA
    government-wide.

-   The President's Information Technology Advisory Committee issued a
    Report to the President, February 2005, "Cyber-Security: A Crisis of
    Prioritization." This report concludes a year-long study of the
    security of IT infrastructure of the U.S., with particular attention
    to intentional attacks, considering the potential impacts to
    national and homeland security, as well as everyday life of all
    American citizens. This report provides suggestions to improve the
    Nation's cyber-security.

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

As can be seen from the many GAO reports noted above, there are many
challenges that must be addressed regarding the integration,
performance, funding, security, and data integrity of IT systems
generally. Like other federal agencies, Interior must address these
challenges for its 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 here impede progress in
achieving Interior's IT management goals:

**Litigation**

-   Collection and production of documents and court appearances have
    placed significant strain on available staff and contractor
    resources throughout most of this reporting period, resulting in
    substantial delays in accomplishing planned and required work. The
    extent of the effort required for this document production resulted
    in significant backlogs and rescheduling that will hamper Interior's
    efforts for months to come. Production of documents has exceeded 4.5
    million pages. Examples of impacted actions include:

    -   FISMA compliance actions

    -   Interior's financial audit

    -   OMB and Congressional reporting requirements

    -   Migration to a single e-mail messaging system

    -   Migration to a single Active Directory system

    -   Complying with HSPD-12 for implementing E-Authentication in
        Interior

    -   Delay in moving Interior bureaus and offices to a single WAN

-   Employee fears about becoming personally implicated in the *Cobell*
    litigation have been heightened as individuals from varying levels
    in Interior have been required to testify at the evidentiary
    hearing. These fears continue to undermine communication and
    decision-making, and along with burn-out from demands for volumes of
    document production, are contributing factors to low employee
    morale.

**Funding**

-   Considerable expense was incurred as a result of collecting and
    producing over 4.5 million pages of material for the litigation.
    This expense diminished the funding available for security
    improvement and program evaluation.

-   Funding availability will continue to dictate the timing of
    IT-related initiatives. Interior's FY2005 and FY2006 budgets will
    require managing a variety of IT-related requirements and tradeoffs.

**Staffing**

Interior is experiencing high staff and management turnover in critical
IT positions, particularly IT security. Resulting impacts to
communication, efficiency, and oversight are impeding IT security
service area functions.

**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. Maintaining
security on internal systems is more difficult without access to the
Internet for research, reporting, and patch management. Similarly,
promulgation of policy and training is substantially hampered by the
lack of interconnectivity and Internet access.

**[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-Two*. The information provided in this section is accurate to the
best of my knowledge.

Date: August 1, 2005

Name: *Signature on File*

W. Hord Tipton

Interior Chief Information Officer

A.  []{#__RefHeading___Toc110653576 .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}**

**Inventory of Cadastral Needs**

The development of a FY2006, FY2007 and FY2008 nationwide inventory of
requests for cadastral survey services in Indian country was a major
focus of BLM and BIA during this reporting period.

Approximately 1,280 survey services with an estimated cost of \$75.9
million dollars were requested for FY2006, FY2007 and FY2008. The
breakout for survey services requested for each year is as follows:
FY2006, 565 requests at an estimated cost of \$40.8 million dollars;
FY2007, 545 requests at an estimated cost of \$25.8 million dollars; and
FY2008, 170 requests at an estimated cost of \$9.3 million dollars. BLM
and BIA used CARS to determine the highest priority of the requested
surveys, and to aid in the distribution of the proposed appropriation of
eight million dollars for survey services to be performed during FY2006.
The proposed appropriation for cadastral survey services is expected to
facilitate completion of Indian trust projects valued as high as \$90.5
million dollars.

**Educational Opportunity and Outreach**

BLM and the Oregon Institute of Technology have agreed to a cooperative
partnership and have signed an assistance agreement during this
reporting period. The objective of this agreement is to emphasize the
public land surveying curriculum and to partner with American Indian
Tribes and organizations to promote and encourage survey education for
individual Indians.

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

**Interior Indian Trust Lands Boundary Standards (Draft)**

The Draft Boundary Standards were revised based upon comments received.
The standards and comments received are currently being reviewed by SOL.
Upon completion of SOL review, an updated draft will be provided to
agencies and other affected parties.

**Funding of the Recommendations Outlined in the FTM**

During this reporting period, the FY2006 budget necessary to achieve the
FTM goals as they relate to cadastral surveys was agreed to be funded by
OST in the amount of \$2,075,000. This funding will assist BLM in the
hiring of 12 BLM Indian land surveyors to be located at BIA regional
offices.

The BLM Indian land surveyors for the Midwest and Northwest Regions have
been hired and have reported to their respective duty locations. The BLM
Indian land surveyors for the Southern Plains, Eastern Oklahoma and
Navajo Regions are hired and are currently scheduled to report during
the next reporting period. The Great Plains BLM Indian land surveyor
position was re-advertised at the end of this reporting period and it is
anticipated that the individual selected will also report during the
next reporting period. The remaining six BIA regions are expected to
receive their BLM Indian land surveyors in FY2006.

The Certified Federal Surveyor (CFedS) program is one of the FTM
components for BLM. During this reporting period, a CFedS design
committee provided a design of the concept and implementation process
for CFedS. The CFedS project manager position is expected to be
advertised at the BLM National Training Center during the next reporting
period. The final implementation plan is expected to be developed in
FY2005, with the first CFedS certification expected to be awarded in
FY2006.

**Missing BIA Indian Service Survey Records and Unofficial Survey
Records**

BLM has sent two experienced land surveyors to the AIRR to search for
any survey-related records or unofficial survey plats or maps that may
assist them to properly and legally identify, locate, survey or resurvey
Indian lands. As a result of their investigation, BLM believes that
there is no significant amount of Indian survey records at this one
facility. Further, they believe that there is no one facility housing
any significant amount of these records. These records could possibly be
located at the various NARA facilities, local agency offices, tribal
facilities, other storage facilities and possibly private collections.
BLM will continue the search for any records or documents that may
assist them in defining Indian lands. Further reporting on this matter
will be limited to significant developments.

**[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. 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-Two*.
The information provided in this section is accurate to the best of my
knowledge.

Date: July 21, 2005

Name: *Signature on File*

Donald A. Buhler

Chief Cadastral Surveyor

Bureau of Land Management

B.  []{#__RefHeading___Toc110653577 .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 started a new rulemaking process for the valuation of oil produced
from tribal and allotted Indian lands. In anticipation of publishing
this new proposed rule, MMS held consultations with Indian tribes and
individual Indian mineral owners during this reporting period, to gather
additional comments on the draft proposal. As previously reported, a
proposed rule for valuing crude oil produced from Indian leases is
expected to be published by August 31, 2005.

**Payment Receipt Date Verification**

With the successful completion of the PeopleSoft upgrade, in January
2005, software changes and system enhancements are being user-tested.
Once implemented, further errors are expected to be prevented. MMS
expects to devote resources to identify prior errors in the Indian
mineral revenue distribution file.

**[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-Two*. The information provided in this section is accurate to the
best of my knowledge.

Date: July 18, 2005

Name: *Signature on File*

Cathy J. Hamilton

Chief of Staff

Minerals Revenue Management

Minerals Management Service

C.  []{#__RefHeading___Toc110653578 .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.

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

**Judgment IIM Accounts**

OHTA continues to perform historical accounting procedures on Judgment
IIM accounts. OHTA received the electronic IIM transaction data files it
uses for the Judgment IIM account historical accounting in 2003 from one
of its contractors, which had received the data files directly from OST
in 1999; the data files were received by OHTA from a system that was not
connected to the Internet. Since its 2001 inception, neither OHTA nor
its contractors have stored the data on a system that was connected to
the Internet. During this reporting period, OHTA completely reconciled
an additional 3,718 accounts in Subgroups[^2] as follows: 163 accounts
in Subgroup A, 1,777 accounts in Subgroup B, 752 accounts in Subgroup C,
and 1,026 accounts in Subgroup D. Of the 43,764 Judgment IIM accounts
completely reconciled as of June 30, 2005, quality control review has
been completed for 43,032. OHTA expects to complete quality control
review of the other 732 completely reconciled accounts during the next
reporting period.

As more data---particularly from the "Paper Records Era"---are collected
and keyed into the transaction listings, some accounts are reclassified
into Subgroups different from their original classification. The
following tables present the total number of Judgment IIM accounts in
each Subgroup reconciled as of June 30, 2005, including accounts
reconciled in previous reporting periods. The tables also report
balances and throughput.

![](media/image3.wmf)

![](media/image4.wmf)

A majority of the remaining Judgment IIM accounts (as well as some Per
Capita IIM accounts) require conversion of transaction data from manual
ledgers to electronic format. As of June 30, 2005, OHTA has searched
approximately 4,750 boxes of stored records for manual ledgers required
to complete the account history for Judgment and Per Capita IIM accounts
that originated in the "Paper Records Era." Approximately 260,000
transactions for 27,000 Judgment and Per Capita IIM accounts have been
located and entered into electronic format as a result of this effort.

**Per Capita IIM Accounts**

OHTA continues to perform historical accounting procedures on Per Capita
IIM accounts. OHTA received the electronic IIM transaction data files it
uses for the Per Capita IIM historical accounting in 2003 from one of
its contractors, which had received the data files directly from OST in
1999; the data files were received by OHTA from a system that was not
connected to the Internet. Since its 2001 inception, neither OHTA nor
its contractors have stored the data on a system that was connected to
the Internet. During this reporting period, OHTA completely reconciled
an additional 843 accounts in Subgroups[^3] as follows: 95 accounts in
Subgroup B, 583 accounts in Subgroup C, and 165 accounts in Subgroup D.
Of the 8,401 Per Capita IIM accounts completely reconciled as of June
30, 2005, quality control review has been completed for 7,558 accounts.
OHTA expects to complete quality control review of the other 843
completely reconciled accounts during the next reporting period.

As more data---particularly from the "Paper Records Era"---are collected
and keyed into the transaction listings, some accounts are reclassified
into Subgroups different from their original classification. The
following tables present the total number of Per Capita IIM accounts in
each Subgroup reconciled as of June 30, 2005, including accounts
reconciled in previous reporting periods. The tables also report
balances and throughput.

![](media/image5.wmf)

![](media/image6.wmf)

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

During this reporting period, OHTA mailed an additional 250 Historical
Statements of Account with an accompanying transmittal letter explaining
the Statement, bringing the total number of Statements mailed to
Judgment IIM account holders to 12,122. A toll-free telephone number is
available to account holders and/or their parents or guardians in the
event they have questions about the mailings. Since OHTA began mailing
Statements, approximately 2 % of the Statement recipients have inquired
regarding their Statements, the substantial majority of which related to
the reason the Statement was provided to the account holder. The
remaining 4,974 Statements could not be mailed to Judgment IIM account
holders because no known addresses were available. With this latest
mailing, OHTA completed the mailing of all deliverable Statements in the
group of 17,096 Statements that the Court permitted OHTA to transmit to
account holders in its October 22, 2004, Order.

Of the 12,122 Statements mailed, 11% were returned as undeliverable for
various reasons. OHTA has re-mailed Statements using forwarding
addresses provided by the U.S. Postal Service, and by TFAS/Trans Union
and Bank of America search services. Returned Statements will continue
to be re-mailed as forwarding addresses become available.

**Land-Based IIM Accounts**

OHTA continues to conduct reconciliation work on High-Dollar
Transactions identified as equal to or in excess of \$100,000, and on
National Sample Transactions under \$100,000 in Land-Based IIM accounts.
A final report on this work is expected later in FY2005 when
reconciliation is completed. OHTA received the electronic IIM
transaction data files it uses for the Land-Based IIM reconciliations in
2003 from one of its contractors, which had received the data files
directly from OST in 1999; the data files were received by OHTA from a
system that was not connected to the Internet. Since its 2001 inception,
neither OHTA nor its contractors have stored the data on a system that
was connected to the Internet.

**Note: This section continues on the next page.**

**OHTA SDA Distribution Project**

The results of the OHTA SDA Distribution Project, as of June 30, 2005,
are provided in the following table.

**SDA Distribution Progress**

+---------------------------------------------+---------+---+------------+
|                                             | *       |   | > *        |
|                                             | *Number |   | *Dollars** |
|                                             | of**    |   |            |
|                                             |         |   |            |
|                                             | **Acc   |   |            |
|                                             | ounts** |   |            |
+---------------------------------------------+---------+---+------------+
| > SDA that remained to be resolved as of    | 12,598  |   | > \$       |
| > March 31, 2005 -\                         |         |   | 32,336,679 |
| > Reported in the *Status Report to the     |         |   |            |
| > Court Number Twenty-One*                  |         |   |            |
+---------------------------------------------+---------+---+------------+
|                                             |         |   |            |
+---------------------------------------------+---------+---+------------+
| > Interest posted on undistributed SDA and  | \--     |   | > (        |
| > additional                                |         |   | 1,253,018) |
| >                                           |         |   |            |
| > collections credited to SDA during this   |         |   |            |
| > reporting period - net of disbursements   |         |   |            |
| > exceeded additional collections resulting |         |   |            |
| > in a net negative figure                  |         |   |            |
+---------------------------------------------+---------+---+------------+
| > []{.mark}                                 |         |   |            |
+---------------------------------------------+---------+---+------------+
| > SDA resolved during this reporting period | [(377   | > | [(3,6      |
|                                             | )]{.und |   | 24,301)]{. |
|                                             | erline} | [ | underline} |
|                                             |         | ] |            |
|                                             |         | { |            |
|                                             |         | . |            |
|                                             |         | m |            |
|                                             |         | a |            |
|                                             |         | r |            |
|                                             |         | k |            |
|                                             |         | } |            |
+---------------------------------------------+---------+---+------------+
|                                             |         |   |            |
+---------------------------------------------+---------+---+------------+
| SDA remaining to be resolved as of June 30, | 12,221  | [ | \$         |
| 2005                                        |         | ] | 27,459,360 |
|                                             |         | { |            |
|                                             |         | . |            |
|                                             |         | m |            |
|                                             |         | a |            |
|                                             |         | r |            |
|                                             |         | k |            |
|                                             |         | } |            |
+---------------------------------------------+---------+---+------------+

The following table reflects the SDA dollars resolved by type of
recipient during this reporting period. Recipients in the "other"
category include transfers to the Miscellaneous Receipts Account at
Treasury, account reclassifications and transfers to the Federal Finance
System.

<table style="width:100%;">
<colgroup>
<col style="width: 31%" />
<col style="width: 12%" />
<col style="width: 1%" />
<col style="width: 12%" />
<col style="width: 1%" />
<col style="width: 13%" />
<col style="width: 1%" />
<col style="width: 12%" />
<col style="width: 1%" />
<col style="width: 12%" />
</colgroup>
<tbody>
<tr class="odd">
<td></td>
<td><blockquote>
<p><strong>Transfers<br />
to IIM Accounts</strong></p>
</blockquote></td>
<td></td>
<td><blockquote>
<p><strong>Transfers<br />
to Tribal Accounts</strong></p>
</blockquote></td>
<td></td>
<td><blockquote>
<p><strong>Paid to Non-Indian Third Party</strong></p>
</blockquote></td>
<td></td>
<td><blockquote>
<p><strong>Other</strong></p>
</blockquote></td>
<td></td>
<td><blockquote>
<p><strong>Total</strong></p>
</blockquote></td>
</tr>
<tr class="even">
<td><blockquote>
<p>Dollars resolved during this reporting period</p>
</blockquote></td>
<td><blockquote>
<p>$892,914</p>
</blockquote></td>
<td></td>
<td><blockquote>
<p>$1,408,950</p>
</blockquote></td>
<td></td>
<td><blockquote>
<p>$166,278</p>
</blockquote></td>
<td></td>
<td><blockquote>
<p>$1,156,159</p>
</blockquote></td>
<td></td>
<td>$3,624,301</td>
</tr>
</tbody>
</table>

**Interest Recalculation**

In the January 6, 2003, *Historical Accounting Plan for Individual
Indian Money Accounts*, Interior planned to recalculate expected
interest payments in each IIM account. Historical accountings for
Judgment and Per Capita IIM include an interest recalculation. Also, OST
performs an interest recalculation on all SDA distributions for each
recipient of previously undisbursed SDA funds in the OHTA population.

During this reporting period, OHTA directed its contractor to begin this
process for Land-Based IIM accounts. Completion of the interest
recalculation effort will account for approximately 40% of the total
number of transactions in land-based accounts and will help facilitate
the identification and resolution of data gaps in the electronic
records.

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

OHTA's IIM imaging and coding efforts continued during this reporting
period. Updates to the *Coding and Imaging Manual* were released on May
24, 2005. Updates included a new section detailing the requirements for
imaging documents to be loaded into OHTA's Accounting Reconciliation
Tool.

As of June 30, 2005, OHTA had completed the following imaging and coding
work.

**[Imaging and Coding Progress]{.underline}**

  -------------------------- ------------------------ ---------------------- ----------------------
                             **[Pages                 **[Documents           **Documents Loaded
                             Scanned]{.underline}**   Coded]{.underline}**   into Accounting
                                                                             [Reconciliation
                                                                             Tool]{.underline}**

  Work results from July 9,  7,067,045                238,866                237,006
  2003 (commencement of                                                      
  imaging and coding),                                                       
  through March 31, 2005 --                                                  
  Reported in the *Status                                                    
  Report to the Court Number                                                 
  Twenty-One*                                                                

  Work results during this   [693,145]{.underline}    [18,100]{.underline}   [14,947]{.underline}
  reporting period                                                           

  Cumulative results through 7,760,190                256,966                251,953
  the end of this reporting                                                  
  period                                                                     
  -------------------------- ------------------------ ---------------------- ----------------------

[]{.mark}

**Observations on Quality of Data and Supporting Documents**

As OHTA's five professional accounting firms have performed
reconciliations of the various types of IIM accounts and transactions,
they have reported no evidence of fraudulently altered documents or
unauthorized access to computer systems.

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

OHTA's ability to search for trust records necessary to its ongoing
historical accounting projects was impacted during portions of this
reporting period by limited access to certain records, including: (1)
records being prepared for shipment, in transit to the AIRR, or being
processed by NARA; and (2) records held in Albuquerque because of Court
orders in *Pueblo of Laguna v. United States*, *Jicarilla Apache v.
United States*, and *Osage Nation and/or Tribe of Indians of Oklahoma v.
United States*.

[]{.mark}

The enacted appropriations for FY2003 through FY2005 have been below the
President's requests. This has prevented OHTA from making the progress
it projected in the January 6, 2003 Plan, filed with the Court.

OHTA has now completed the mailing of all deliverable Statements in the
group of 17,096 Statements that the Court has permitted OHTA to transmit
to account holders. An additional 28,107 Statements have been awaiting
Court approval for mailing since March 24, 2005.

**[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-Two*. The information provided in this section is accurate
to the best of my knowledge.

Date: July 28, 2005

Name: *Signature on File*

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

III. []{#__RefHeading___Toc110653579 .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. In addition to other trust

reform--related duties assigned by the Secretary, the Special Trustee
accepted the transfer of the Office of Appraisal Services from BIA to
OST.

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

**Trust Initiatives for the 21^st^ Century**

During this reporting period, a major FTM implementation milestone was
reached at the two BIA pilot agencies, Concho and Anadarko. As of June
30, 2005, these two agencies completed the process of converting their
systems to the new TAAMS title system and TAAMS leasing system, both of
which are now working as an integrated system with TFAS. During the next
reporting period, statements of account that contain trust asset
ownership information as well as the status of deposits and balances of
funds are expected to be sent to beneficiaries of these two agencies. A
schedule for systems conversion at the other agencies is expected to be
completed during the next reporting period.

Final approval of the functional requirements for the next generation of
land management software, DLRM, was given by the affected bureaus and
offices during this reporting period. It is expected that an RFP can be
released by the end of CY2005.

As part of FTM implementation, BLM began hiring surveyors to be
stationed at BIA regional offices. Their presence is expected to help
expedite survey requests, prioritize requests and determine when surveys
are actually needed, to avoid unnecessary surveys. The remaining
regional surveyors are expected to be hired during FY2006.

During this reporting period, an Interior Regulatory Initiative was
begun to develop regulations that further the implementation of the FTM,
comply with requirements of AIPRA, and streamline other business
processes. The Regulatory Initiative working groups consist of employees
from BIA, OST, BLM, NBC, SOL, OHA and OHTA. Some of the draft
regulations are expected to be published by the end of CY2005.

OTR was organized within OST to improve the records management within
Indian

affairs-related bureaus and offices. Since September 2002, OTR has been
managed directly by the Assistant Deputy Secretary. During this
reporting period, management of OTR began moving from the Assistant
Deputy Secretary to OST. In the future, OTR will be under the direct
management of the CIO for OST. The records assessment function has been
transferred to OTRA so that records assessments can be done in
coordination with regular reviews and audits of other trust functions.
OTRA will continue to report to the Court as a separate administrative
function.

**American Indian Probate Reform Act**

The required notice to Indian landowners was completed during this
reporting period. Certification of the notice was made by the Secretary
so that the required one year period for implementation of many sections
of the Act has begun to run. Consideration is being given to enlist
non-profit organizations to assist with drafting wills and doing estate
planning for individuals affected by the Act.

**Appraisals**

During this reporting period, the deputy to the Chief Appraiser of the
Appraisal Services Directorate reported for duty. However, after two
weeks on the job, this person decided to return to his previous
employment. The Chief Appraiser is now in the process of advertising
this position and expects to have a selection by the end of this
calendar year.

A week of appraisal training and review of policies and procedures is
scheduled for the first week of August 2005. This training will be for
all OAS appraisers and staff. The training is expected to focus on the
appraiser's "Yellow Book" standards and USPAP.

The reappraisal of the Navajo rights-of-way reported on in the last
report was completed during this reporting period. The appraisals are
under review and results of the appraisals are expected to be available
during the next reporting period. A policy for appraising renewal of
rights-of-way was released by the Chief Appraiser during this reporting
period and has been made available to the field appraisers for their
use.

Several review appraisers were hired during this reporting period as
reported in the Appraisal section of this report. The Director continues
to report problems in hiring sufficient staff to meet the appraisal
needs.

**[Conclusion]{.underline}**

Reform of the fiduciary trust is proceeding. The conversion at the
Concho and Anadarko pilot agencies demonstrates that the FTM can be
implemented, and provides the business process tools to BIA to manage
its part of the fiduciary trust. While obstacles remain, I believe that
the foundation for fiduciary trust reform has been laid and that
building on this foundation will allow Interior to execute more
efficiently its legal obligations to trust beneficiaries.

**[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: July 26, 2005

Name: *Signature on File*

Ross O. Swimmer

Special Trustee for American Indians

A.  []{#__RefHeading___Toc110653580 .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.

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

**Indian Trust Examinations**

During this reporting period, OTRA performed 11 trust reviews. Three
draft reports were issued for comment and 16 final reports were issued.

On May 1, 2005, OTR transferred three employees to OTRA to perform trust
records management assessments for Interior. This transfer facilitates a
separation of duties between records training and management and the
assessment function. Future reporting on trust records assessments will
be provided by OTRA. Since the transfer, OTRA has completed seven trust
record assessments and expects to issue either draft or final reports
during the next reporting period.

**Annual Interior Indian Trust Funds Financial Statement Audit**

The Indian trust funds financial statement audit, required by the
American Indian Trust Fund Management Reform Act of 1994, is conducted
by an independent auditor under OIG management. The independent auditor
continued work on the FY2005 audit during this reporting period and is
expected to complete work during the first quarter of FY2006.

**Annual Audit Corrective Actions**

During this reporting period, in response to the FY2004 audit, OST
managers reported continued progress on implementing corrective action
plans addressing material weaknesses, non-compliance issues and
management letter comments.

**Compliance Reviews**

Compliance reviews are generated by information received from
beneficiaries, employees and the public. During this reporting period,
10 cases were in inventory. Two cases were closed and final reports
issued. Field work or report drafting continued on the remaining eight.

**[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-Two*. The information provided in this section is accurate to the
best of my knowledge.

Date: July 20, 2005

Name: *Signature on File*

D. Jeff Lords

Acting Director, Office of Trust Review and Audit

Office of the Special Trustee for American Indians

B.  []{#__RefHeading___Toc110653581 .anchor}**OST-OFFICE OF THE CHIEF
    INFORMATION OFFICER**

```{=html}
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1.  []{#__RefHeading___Toc110653582 .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**

During this reporting period, approximately 560 boxes of inactive Indian
records were moved to the Annex in Lenexa, KS, from OTR's facilities in
Albuquerque, NM. Boxes that are collected and need to be indexed are
sent to the Annex for indexing prior to being placed in AIRR.
Approximately 119,570 indexed boxes are located in the AIRR as of the
end of this reporting period. 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 126,437 cubic feet of indexed records at AIRR. OTR
will begin including NARA's measure as well in future reports.

**Records Indexing Project**

Indexing of approximately 120,110 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 are sent to AIRR from the Annex before
the end of the reporting period. Priority for the indexing of boxes of
Indian records continued to be given to those boxes of records
potentially responsive to tribal trust litigation, and included boxes
required by OHTA for litigation discovery requests.

Approximately 4,550 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.

During the past reporting period, the electronic data base containing
the index of records was identified by Interior as a separate system of
records. As a result, an assessment of the system was required to
determine if the system met the conditions of the Privacy Act. During
the indexing of records, some information is entered into the electronic
data base that may contain personal identifiers (such as a name and
account number). Therefore, the electronic Box Index Search System has
been classified as a Privacy Act system of records by Interior. The
Privacy Act notice has been prepared and is being circulated within
Interior for surname and signature. It is anticipated that a Federal
Register notice soliciting public comments will be published during the
next reporting period.

**Training**

OTR provided records management training for 199 BIA and 17 OST
identified records contacts during this reporting period.

**Equipment Purchases**

The existing contract, to supply fireproof filing equipment, was
modified during the reporting period to increase the contract amount. It
is anticipated that pending requests for equipment will be filled during
the next reporting period.

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

**Safeguarding Records**

The 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 on June 30, 2005. Two additional
boxes were identified during final shipments of the collection as
requiring remediation. The two boxes were assessed in June by Carino
Conservation and were also sent to NARA for remediation bringing the
total number of such boxes to 285. The actual box count for purposes of
shipment was 284 as two map groups were consolidated as one box in order
to ship.

**Record Keeping Requirements**

During the reporting period, written comments on the proposed language
for management of fiduciary trust records were received and considered
from approximately 60 tribal leaders, staff and consultants. The
proposed language was modified in light of comments received. The final
language will be used in negotiations for FY2006 annual funding
agreements with compacted and contracted Tribes. The final negotiation
guidance is anticipated to be published in the Federal Register during
the next reporting period.

**Site Assessments**

OTR conducted three records management site assessments of BIA and OST
programs located at the Southwest Regional Office and Concho Agency and
at the Navajo Regional OST field office during the reporting period.

During this reporting period, OTR completed and distributed site
assessment reports to BIA programs located at: Southern Pueblos Agency,
Jicarilla Agency, Concho Agency, Mescalero Agency, Eastern Oklahoma
Regional Office, Southwest Regional Office and Ute Mountain Ute Agency.
Site assessments reports were also completed and sent to the Principal
Deputy Special Trustee for OST programs located at: Southwest Regional
Office, Navajo Regional Office, and Concho Agency.

In May 2005, the responsibility for conducting site assessments of trust
records management for BIA and OST was transferred to OTRA. This office
is now responsible for conducting trust site assessments and issuing
site assessment reports. Appropriate OTR personnel were transferred
along with the transfer of function. Beginning with this report, OTRA
will include a report on the status of site assessments in its section
of the *Status Report to the Court*.

**Records Retention Schedules**

Following receipt of BIA approval, OTR sent the following electronic
systems records schedules to the Archivist of the United States for
approval: Anadarko Real Estate Module (REM); Indian Forestry Database
(InfoDat); Continuous Forest Inventory (CFI); and Geographic Information
System (GIS). OTR is awaiting approval of the schedules; however, NARA
has pending to OTR a request for additional technical analysis related
to the GIS schedule.

**Records Evaluation**

As previously reported, 31 boxes set aside for evaluation remain at OTR
in Albuquerque pursuant to a litigation hold. Once the boxes are
released, OST expects to verify whether any potential records in these
boxes are also filed at the OST SWRO. OST expects to conduct this
verification when SOL informs OST that the boxes can be returned to OST.

**[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.

**[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-Two.* The information provided in this section is accurate to the
best of my knowledge.

Date: July 19, 2005

Name: *Signature on File*

Ethel J. Abeita

Director, Office of Trust Records

Office of the Special Trustee for American Indians

A.  []{#__RefHeading___Toc110653583 .anchor}**TRUST ACCOUNTABILITY**

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1.  []{#__RefHeading___Toc110653584 .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}**

The General Guidance and References handbook (containing commonly used
acronyms, general authorities, etc.) was completed, approved by BIA, and
put into use by the handbook teams.

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

**FTM - General**

A FTM communication plan has been developed to provide strategy and
tactics for communicating FTM initiatives to all affected audiences.
Reengineering staff began incorporating the plan into FTM implementation
schedules to ensure both internal and external parties receive
appropriate information.

A site visit was performed at one BIA agency to discuss FTM-related
training curriculum development. Comments were solicited from employees
relative to personal training preferences to assist in the completion of
the FTM training task deliverable.

Reengineering staff participated in two Interior Regulatory Initiative
meetings. Staff and team members identified regulations impacted by the
FTM, and began drafting new and amended regulations to support the FTM.

Comments from senior management regarding direct pay and fee interests
in trust parcels have been forwarded to the Regulatory Initiative group
for their consideration and drafting of regulations.

During this reporting period, several draft BIA handbooks were sent to a
contractor for editing and formatting, with handbook drafting and review
expected to continue through CY2005.

**Trust Beneficiary Call Center**

Since beginning operations in December 2004 through the end of this
reporting period, the TBCC received 32,129 calls and provided a
first-line resolution for 92.7% (29,782) of these calls. Currently,
toll-free calls have been re-directed to the TBCC from the Southern
Plains, Eastern Oklahoma, Pacific and Western Regions. During this
reporting period, the TBCC provided a first line resolution for 7,779
calls from beneficiaries serviced by these regions. Based on an average
call time of 03:15, the TBCC provided 421 hours of time available to
staff at the agencies for other purposes. Re-directing all toll-free
calls to TBCC is scheduled to be completed by the end of CY2005.

During this reporting period, access to the TBCC tracking system was
provided to the FTOs and staff to allow recording and documenting of all
types of beneficiary contact. Use of the same tracking system database
by the TBCC and field locations should result in beneficiaries receiving
consistent and timely responses.

**Universal Support Function**

Reengineering staff completed draft skills models for BIA Real Estate
Services, Natural Resources, Forestry, Probate, Title, OST Trust
Services and a General Skills model. It is expected that during the next
reporting period, skills models for OST Field Operations and Appraisals
and BIA Energy & Minerals will be drafted. All are expected to be
completed by the end of FY2005.

Reengineering staff is currently developing a proof-of-concept model to
fully automate the CSS work ticket process. The process, which is
heavily dependent upon paper faxes, can be automated, with little or no
cost, to reduce significantly the amount of paper records generated. A
concept of operations has been drafted and will be presented to senior
management during the next reporting period.

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

Major obstacles affecting the ability of Interior to build a trust
services delivery model include:

-   lack of Internet access, and

-   sheer complexity of reengineering the existing trust business
    processes to achieve integrated and consistent 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-Two.* The information provided in this section is
accurate to the best of my knowledge.

Date: July 21, 2005

Name: *Signature on File*

John Bennett

Acting Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

2.  []{#__RefHeading___Toc110653585 .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:

-   Encoded 1,563 leases and 796 ROW documents into the TAAMS Realty
    Module for the Anadarko Agency.

-   Encoded 564 leases and 332 ROW documents into the TAAMS Realty
    Module for the Concho Agency.

-   Encoded remaining Concho Agency encumbrance effective/expiration
    dates into the land title system, and OST was notified that the
    remaining Anadarko Agency encumbrances' effective/expiration dates
    were entered into the land title system.

-   Created an inventory of 3,177 performance bonds, of various types,
    for the Concho and Anadarko Agencies.

-   Assisted PRO-LTRO with determining the correct landowner ID number
    in the land title system. Verified remaining 366 of 535
    BIA-certified IDs in the land title system.

-   Scanned trust conveyance documents necessary to perform CDE
    validation/correction for the Cheyenne River Agency.

-   Implemented Post-QA processes at the GPRO-LTRO for all GPRO
    agencies.

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

The DQ&I project continued for: (1) SPRO-LTRO, (2) GPRO-LTRO, (3) Pima
Agency and (4) PRO-LTRO for the Palm Springs Field Office, Northern
California Agency and Southern California Agency.

During this reporting period, TPMC:

-   Supported the Concho Agency with research and correction of
    instances where a beneficiary had been assigned more than one unique
    landowner ID number in the various trust systems. Landowners with
    multiple ID numbers were identified during the CDE
    validation/correction task. Sixty-eight out of 390 landowner IDs
    were researched during the reporting period for a total of 277
    researched and identified to date. The remaining 113 landowner ID
    numbers were identified as belonging to landowners outside the
    Southern Plains Region and will require additional research by the
    responsible BIA agencies.

-   Assisted the Concho Agency to reduce RDRS encoding backlogs by
    encoding five probate orders, nine oil and gas leases, and 25
    landowner ID changes.

-   Supported Fort Belknap Agency\'s SDA distribution efforts, by
    encoding 87 out of 247 probate orders into IRMS, for a total of 133
    probate orders encoded to date. Of the 803 Fort Belknap Agency
    probate orders inventoried, 247 were identified to be encoded by the
    contractor.

-   Assisted PRO-LTRO with conversion cleanup by encoding 100 trust
    patent documents into the land title system.

-   Determined that six of the previously reported 252 Concho Agency CDE
    title variances in the land title system were not in error. In the
    previous reporting period, 231 CDE were corrected and encoded.
    During this reporting period, three CDE were encoded for a total of
    234 to date. Twelve remaining CDE variances require further
    research.

-   Encoded an additional 2,418, for a total of 12,600 Anadarko Agency
    CDE title and encumbrance variances recorded in the land title
    system. Research on the remaining tracts is ongoing but is
    significantly more time-intensive than was previously experienced.
    This research was expected to be completed during the last reporting
    period but was deferred in order to assist Anadarko Agency with its
    conversion to a new realty system.

-   Encoded into the land title system an additional 486 Concho Agency
    CDE and 17,303 Anadarko Agency CDE, which did not exist in the
    former BIA legacy land title system, for a total of 9,973 encoded at
    Concho and 32,184 at Anadarko.

**[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-Two.* The information provided in this section is accurate
to the best of my knowledge.

Date: July 26, 2005

Name: *Signature on File*

John E. White

Trust Reform Officer

Office of the Special Trustee for American Indians

3.  []{#__RefHeading___Toc110653586 .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}**

Cannon Financial Institute personnel presented the *Accounting,
Guardianship, Fiduciary Behavior* and *Asset Management* specialty
courses to 125 OST, BIA, and tribal personnel. These four courses are
part of the previously reported certification program. Additional
sessions of these courses are expected to be presented during the next
reporting period.

During this reporting period, OST training staff conducted 10 sessions
to provide training in TFAS, CSS, StrataVision and the historical query
database to 240 OST, BIA and contractor staff.

Additional training for TFAS, CSS, StrataVision, Historical Query,
TAAMS, ProTrac and Lockbox training was provided to the Concho and
Anadarko agencies' staff.

OST and BIA staff presented the three-day course, *Trust Fundamentals,*
to 34 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.
This course is expected to be presented again during the next reporting
period.

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

Construction continues on the NIPTC in Albuquerque and is expected to be
completed by the end of CY2005.

**[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-Two.* The information provided in this section is
accurate to the best of my knowledge.

Date: July 19, 2005

Name: *Signature on File*

Dianne M. Moran

Director, Trust Training

Office of the Special Trustee for American Indians

4.  []{#__RefHeading___Toc110653587 .anchor}**RISK MANAGEMENT**

**Introduction**

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:

-   BIA provided a point of contact to help coordinate the
    implementation of the risk management program and the RM-PLUS tool
    throughout BIA for the trust programs.

-   The security and risk review was completed for the RM-PLUS tool.

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

The risk management program using the RM-PLUS tool was proposed to the
Cherokee Nation as a pilot Tribe in FY2006.

MMS continued and OSM initiated their identification of business
processes needed to assess and mitigate program risks through the use of
the RM-PLUS tool. BLM and OST continued validation of their
previously-identified business processes and program risk factors.

During the next reporting period, new BIA business processes are
expected to be incorporated into the RM-PLUS tool at the Concho and
Anadarko pilot agencies. Training for OST, BIA, BLM, MMS and OSM is
expected to be provided for the RM-PLUS tool. All assessments utilizing
RM-PLUS should be completed by September 1, 2005.

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

The lack of Internet access complicates the implementation and use of
RM-PLUS, since it was 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-Two*. The information provided in this section is accurate to the
best of my knowledge.

Date: July 21, 2005

Name: *Signature on File*

John Bennett

Acting Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

5.  []{#__RefHeading___Toc110653588 .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.

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

Changes to four chapters of the Account Maintenance Desk Operating
Procedure were completed and issued.

Changes to the policy for handling telephone requests for changes to an
unsupervised IIM account were completed and issued.

Two IT policies were completed and issued: "Email Usage" and "IT Support
Requirements Document."

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

OTP continues to work on amendments to the draft OST Directives System
Handbook. Publication of the handbook is expected by the end of CY2005.

Work continues on the Reporting and Reconciliation and the Disbursing
DOPs. Completion and issuance is expected during the next reporting
period. In addition, work began on an Osage DOP for account maintenance
and disbursement because of statutes and regulations unique to the Osage
Tribe. Completion is expected by the end of CY2005.

**25 CFR 124 -- Deposits of Proceeds of Lands Withdrawn for Native
Selection under the Alaska Native Claims Settlement Act.** During the
reporting period, this final rule was approved and presented to the
Office of the Federal Register for publication. Due to a technical
problem the rule was returned by the Office of the Federal Register and
is now scheduled to be published during the next reporting period.

**25 CFR 1200 -- American Indian Trust Fund Management Reform Act.**
Work continues on this rule and publication is expected by the end of
CY2005.

**[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-Two*. The information provided in this
section is accurate to the best of my knowledge.

Date: July 29, 2005

Name: *Signature on File*

Philip Viles, Director

Office of Trust Regulations, Policies and Procedures

Office of the Special Trustee for American Indians

A.  []{#__RefHeading___Toc110653589 .anchor}**FIELD OPERATONS**

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1.  []{#__RefHeading___Toc110653590 .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}**

The Deputy Chief Appraiser position was filled during this reporting
period. However, the newly appointed Deputy resigned on June 10, 2005.
Actions are underway to advertise and fill the position as quickly as
possible.

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

An Indian Minerals Valuation Unit is being established as a part of ASD
to support the sale and acquisition of minerals on federal and Indian
lands. This is expected to incorporate the FTM's proposed Indian
minerals sale and acquisition initiative. ASD expects to complete the
establishment of the unit during the next reporting period.

ASD, in coordination with OST, continues to conduct a comprehensive
analysis of OAS staffing and training requirements. The position of
Eastern Regional Appraiser has been advertised, and candidates are
currently being interviewed. A selection is expected during the next
reporting period.

The reappraisal of the Navajo rights-of-way reported on in the last
report was completed during this reporting period. The appraisals are
under review and results of the appraisals are expected to be available
during the next reporting period.

Work continued on directives to address the proper appraisal methods and
techniques to be used by OAS appraisers. Directives addressing the
proper appraisal methodology for rights-of-way, and the administrative
shelf-life of appraisals, were issued to regional supervisory appraisers
during this reporting period.

Work continued to revise and update the OAS appraisal handbook, in
conjunction with an updated department-wide appraisal handbook. This
project is expected to be completed during FY2005.

Work continued on the cooperative effort between OAS and NBC to
establish regional contracts with independent contractors to perform
appraisals and alleviate backlogs. Efforts are underway to streamline
the requisition and outsourcing process. This approach will be
duplicated in those regions where this approach may prove to be
successful. The scope of work for a blanket purchase order in the
Northwest Region is still under revision, and is now expected to be
completed during the next reporting period.

OAS filled five review appraiser positions to meet critical needs in the
Great Plains, Rocky Mountain, Midwest and Navajo Regions. Efforts
continue to fill the vacant regional appraiser position in the Northwest
Region. No selection was made during this reporting period. Solicitation
of additional candidates and selection is expected during the next
reporting period.

**Appraisal Backlog**

The appraisal backlogs are as follows:

+--------------------+----------------------+--------------------------+
|                    | **Appraisal          | **Appraisal Backlog**    |
|                    | Backlog**            |                          |
|                    |                      | **[As of                 |
|                    | **[As of             | 6/30/05]{.underline}**   |
|                    | 3/                   |                          |
|                    | 31/05]{.underline}** |                          |
+--------------------+----------------------+--------------------------+
| Northwest          | 166                  | 402                      |
+--------------------+----------------------+--------------------------+
| Rocky Mountain     | 139                  | 592                      |
+--------------------+----------------------+--------------------------+
| Midwest            | 21                   | 38                       |
+--------------------+----------------------+--------------------------+
| Western            | 9                    | 42                       |
+--------------------+----------------------+--------------------------+
| Southwest          | 6                    | 27                       |
+--------------------+----------------------+--------------------------+
| E. Oklahoma        | 33                   | 51                       |
+--------------------+----------------------+--------------------------+
| Navajo             | 203                  | 21                       |
+--------------------+----------------------+--------------------------+
| Pacific            | 13                   | 2                        |
+--------------------+----------------------+--------------------------+
| Alaska             | 318                  | 293                      |
+--------------------+----------------------+--------------------------+
| Eastern            | 0                    | 0                        |
+--------------------+----------------------+--------------------------+
| Southern Plains    | 1                    | 11                       |
+--------------------+----------------------+--------------------------+
| Great Plains       | 80                   | 10                       |
+--------------------+----------------------+--------------------------+
| **Total**          | **989**              | **1,489**                |
+--------------------+----------------------+--------------------------+

This table does not include appraisal backlog information from the
compacted and contracted Tribes. The MOUs that are currently being
negotiated with Tribes require quarterly reporting of backlog
information. This information is expected to be incorporated into future
reports to the Court.

**[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 and hiring qualified appraisers. ASD
is exploring methods to overcome problems experienced with hiring
appraisers.

**[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-Two*. The
information provided in this section is accurate to the best of my
knowledge.

Date: July 26, 2005

Name: *Signature on File*

Brian M. Holly, MAI

Appraisal Services Directorate

National Business Center

A.  []{#__RefHeading___Toc110653591 .anchor}**TRUST SERVICES**

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1.  []{#__RefHeading___Toc110653592 .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 (a) new
accounts established without an address, (b) mail returned for invalid
address and (c) 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.

a.  **Whereabouts Unknown Accounts**

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

During this reporting period, TPMC staff conducted one WAU beneficiary
outreach at the Gathering of Nations Pow Wow in Albuquerque, NM. As a
result of this outreach effort, TPMC received current addresses for 36
WAU account holders.

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

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, 4 of the top 100 WAU accounts,
with combined account balances in excess of \$473,000, were updated with
current addresses. OST now expects to hire a contractor during the next
reporting period to focus on securing current addresses for, or
determining the status of, the top 100 WAU accounts.

During this reporting period, 5,060 accounts with a combined balance of
\$1.8 million were added to the WAU list, and 4,456 account holders with
a combined balance of \$8.7 million were located. As of June 30, 2005,
there were 49,191 WAU accounts with a combined balance of \$68,679,335.
The following table illustrates the number of accounts stratified by
account balance and WAU category:

+----------------+-------------+--------+-----------+-----------+------+
| **Account      | **Corres    | **Acc  | **A       | **R       | *    |
| balance**      | pondence/** | ount** | waiting** | efused/** | *Tot |
|                |             |        |           |           | al** |
|                | **Check     | **S    | **Address | **Un      |      |
|                | Returned**  | etup** | Confi     | claimed** |      |
|                |             |        | rmation** |           |      |
|                |             | **No** |           | **Mail**  |      |
|                |             |        |           |           |      |
|                |             | **Add  |           |           |      |
|                |             | ress** |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Equal to or    | 21          | 9      | 0         | 0         | 30   |
| over \$100,000 |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under          | 38          | 13     | 0         | 0         | 51   |
| \$100,000 and  |             |        |           |           |      |
| equal to or    |             |        |           |           |      |
| over \$50,000  |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under \$50,000 | 2,149       | 834    | 0         | 2         | 2    |
| and equal to   |             |        |           |           | ,985 |
| or over        |             |        |           |           |      |
| \$5,000        |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under \$5,000  | 6,446       | 1,661  | 2         | 5         | 8    |
| and equal to   |             |        |           |           | ,114 |
| or over        |             |        |           |           |      |
| \$1,000        |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under \$1,000  | 9,103       | 3,498  | 3         | 6         | 12   |
| and equal to   |             |        |           |           | ,610 |
| or over \$100  |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under \$100    | 12,388      | 5,187  | 3         | 8         | 17   |
| and equal to   |             |        |           |           | ,586 |
| or over \$1    |             |        |           |           |      |
+----------------+-------------+--------+-----------+-----------+------+
| Under \$1      | 3,562       | 4,235  | 11        | 7         | 7    |
|                |             |        |           |           | ,815 |
+----------------+-------------+--------+-----------+-----------+------+
| **Total**      | **33,707**  | **15   | **19**    | **28**    | **   |
|                |             | ,437** |           |           | 49,1 |
|                |             |        |           |           | 91** |
+----------------+-------------+--------+-----------+-----------+------+

**[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 address for individual
heirs named in probate orders or recipients of per capita distributions.
However, as asset statements are created for non-financial asset owners
without current addresses in the TAAMS title system, WAUs are expected
to increase significantly.

There presently are 18,576 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 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.

b.  **Trust Funds Accounting System**

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

Enhancements to TFAS and the implementation of an interface between TFAS
and TAAMS for use at the pilot agencies were completed during this
reporting period. As a result, account holder statements identifying
sources of income and listing all assets owned at the pilot agencies are
expected to be sent during the next reporting period.

> **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 5,912 receipt transactions
posted to SDA. Of these, 1,043 were undistributed and aged more than 30
days as of June 30, 2005.

During this reporting period, aged funds were held in 32 fewer SDA than
in the previous reporting period. Undistributed aged receipts decreased
by 853 and the combined dollar amount decreased by \$2,553,368.94. As of
June 30, 2005, funds were held in SDA with a combined dollar amount of
\$3,132,093.14, which represented 4,409 undistributed receipts aged over
30 days from January 1, 2003, through June 30, 2005. As of June 30,
2005, there were 1,314 receipts in 301 SDA aged more than one year for a
combined dollar amount of \$863,330.39.

During this reporting period, OST concentrated on assisting BIA staff in
performing work necessary to distribute aged receipts at the Pima and
Eastern Navajo agencies. OST staff and contractors spent a combined four
weeks at these agencies. Through these efforts, in coordination with the
efforts of BIA, aged receipts totaling \$2.5 million were distributed
from SDA during the reporting period.

During this reporting period, OST contractors also continued to assist
Pima and Fort Belknap agencies to reduce their backlogs by encoding
probate orders into BIA's legacy realty system. Reducing their backlogs
assists these agencies with their SDA distribution efforts.

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

Some BIA agencies still are not utilizing StrataVision to obtain current
aging reports to assist in the monitoring and management of their SDA
receipt activity. OST continues to make training available to encourage
the use of StrataVision.

d.  **Small Balance Accounts**

As of June 30, 2005, there were 14,289 accounts that have a \$.01 -
\$1.00 balance with no activity for the previous 18 months. The total
sum included in those accounts is \$2,043.58. Statements are sent to
account holders for these accounts on an annual basis pursuant to
direction from Congress.

**e. Accounting Discrepancies**

Interior's proposal to resolve the difference between the subsidiary
account ledger (liabilities) and the IIM investment pool (assets), of
approximately \$6 million, has been approved by OMB. A legislative
proposal has been submitted to congressional staff with a request that
it be introduced.

**Note: This section continues on the next page.**

**[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-Two*. The information
provided in this subsection is accurate to the best of my knowledge.

Date: July 25, 2005

Name: *Signature on File*

Margaret Williams

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-Two*, and this information
is accurate to the best of my knowledge.

Date: July 21, 2005

Name: *Signature on File*

John Bennett

Acting Deputy Special Trustee, Trust Accountability

Office of the Special Trustee for American Indians

IV. []{#__RefHeading___Toc110653593 .anchor}**BUREAU OF INDIAN AFFAIRS**

    A.  []{#__RefHeading___Toc110653594 .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}**

**National Environmental Policy Act Compliance Handbook --** The
handbook supporting 59 IAM was published during the reporting period.

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

A Regulatory Initiative is underway within Interior to develop and
update trust-related regulations. The following previously-reported
regulations are included in this Initiative:

-   **25 CFR 151 -- Land Acquisitions**

-   **25 CFR 162 -- Leases and Permits**

-   **25 CFR 166 -- Grazing Permits**

-   **25 CFR 216 -- Surface Exploration, Mining, and Reclamation of
    Lands**

Development of handbooks associated with these regulations is expected
to be deferred until such time as the Regulatory Initiative is complete.

**25 CFR 161 -- Navajo Partitioned Lands Grazing Permits --** The Navajo
Nation\'s Intergovernmental Relations Committee met and approved the
final rule. The rule is expected to be published in the Federal Register
during the fourth quarter of FY2005.

**25 CFR 169 -- Rights-of-Way Over Indian Lands --** The Rights-of-Way
Handbook is in final editing.

**25 CFR 243 -- Reindeer in Alaska --** Publication was delayed and is
now expected by the end of CY2005.

**BIAM Conversion to IAM**[^4]

**35 BIAM Information Resources Management --** Revisions have been
incorporated into a new 60 IAM. Publication is expected in the fourth
quarter of FY2005. The handbook is expected to be published by the end
of the fourth quarter FY2005.

**[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-Two*. The information provided in this
section is accurate to the best of my knowledge.

Date: July 26, 2005

Name: *Signature on File*

Bruce Blanchard

Director, Office of Planning and Policy Analysis

Bureau of Indian Affairs

A.  []{#__RefHeading___Toc110653595 .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 24,693 fractional interests during this reporting period,
    for a cumulative total of 162,589 interests for ILCP in the Midwest,
    Northwest, Western, Eastern Oklahoma, Navajo, Rocky Mountain and
    Great Plains Regions.[^5]

-   Of the total interests acquired, 88% were interests of less than 2%
    ownership in the respective tracts of land.

-   Acquired a cumulative total equivalent of 153,965.95 acres for the
    project reservations.

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

ILCO continues to manage active acquisition programs for 18 reservations
within seven BIA regions. ILCO had expended all funding available to
acquire fractionated interests by June 1, 2005. ILCO received \$7.6
million from OST to continue acquisition activities. Presently, all
acquisition sites are utilizing these funds to process land sale
applications.

Due to the volume of beneficiary requests to sell their land interests,
the annual appropriations for purchases and additional funding from OST
are expected to be exhausted before the end of FY2005. During this
period, ILCO expects to use its program staff to prepare for
acquisitions during the next fiscal year, subject to available funding.

Current ILCP activities include:

-   Implementing ILCO's national expansion strategy.

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-   Targeting and acquiring *Youpee* interests.

-   The Land Consolidation Tracking System development, which has been
    delayed and is now expected to be operational and available to all
    ILCP acquisition sites by the end of the next reporting period.

-   Testing of the MAD/LCP, which continues on one of twelve agencies in
    the Great Plains Region. Testing has been completed on the other
    eleven agencies.

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

-   Providing support to the Great Plains and Southwest Regional LTROs
    to assist with recording ILCP deeds, re-vesting *Youpee* interests,
    researching ownership files and recording to ownership records
    reduces the availability of ILCP funds for acquisitions of land
    interests.

-   Probate backlog and *Youpee* issues continue to impede the
    land-purchase transaction process.

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

**[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-Two.* The information provided in this section is accurate to the
best of my knowledge.

Date: July 19, 2005

Name: *Signature on File*

Robert R. Jaeger

Director, Indian Land Consolidation Office

Bureau of Indian Affairs

A.  []{#__RefHeading___Toc110653596 .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. In order to perform
this duty, BIA, OHA and OST must coordinate their work to accomplish the
probate process.

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

**Case Preparation**

Case preparation is the initial stage of the probate process. During
this stage of the process, information is researched and gathered
regarding the identity and whereabouts of presumptive heirs, and an
inventory of the trust assets of an estate is prepared. As of the end of
this reporting period, 9,264 probate cases were in the case preparation
stage.

**Case Adjudication**

In this reporting period, deciding officials received 1,166 cases and
issued decisions in 843 cases.

**Financial Case Closure**

In this reporting period, OST distributed funds and closed 1,469
accounts in TFAS representing 1,439 estates. TFAS, as of the end of June
2005, contained 30,143 open estate accounts, which is an increase of
2,011 from the 28,132 estate accounts at the end of the last reporting
period.

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

**Probate Case Management and Tracking System**

Each BIA regional office and corresponding agency continued the process
of encoding new cases, examining "initial load" cases and making
corrections. Data cleanup continued for this period, with ProTrac now
the source of probate data.

**Probate Handbook**

During this reporting period, the Interior probate handbook was provided
to a contractor for editing and formatting. Publication is expected
during the next reporting period. An addendum to the handbook
incorporating AIPRA is expected to be accomplished after publication of
regulations.

**[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;

-   Fractionation of ownership of Indian lands;

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

-   Cultural diversities regarding the subject of death;

-   Completion of implementation of the probate reorganization.

**[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-two*. The
information provided in this section is accurate to the best of my
knowledge.

Date: July 26, 2005

Name: *Signature on File*

William Titchywy

Acting Special Projects Director

Western Region

Bureau of Indian Affairs

[]{#__RefHeading___Toc110653597 .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

AIPRA American Indian Probate Reform Act

AIRR American Indian Records Repository

ALJ Administrative Law Judges

ARO Alaska Region office

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

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

COTS Commercial off-the-shelf

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

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

ENA Eastern Navajo Agency

EORO Eastern Oklahoma Region office

ERO Eastern Region office

ESN Enterprise Services Network

FAR Federal Acquisition Regulation

FIMO Farmington Indian Minerals Office

FISMA Federal Information Security Management 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

GLAD 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

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

InfoDat Indian Forestry Database

Interior Department of the Interior

IP Internet Protocol

IPJ Indian Probate Judges

IPv6 Internet Protocol Version 6

IRM Information Resources Management

IRMS Integrated Records Management System

IRS Internal Revenue Service

ISA Information Security Assessment

IT Information Technology

IV&V independent verification and validation

LAN Local area network

LCTS Land Consolidation Tracking 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

MWRO Midwest Region office

NARA National Archives and Records Administration

NBC National Business Center

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

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

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

PRO Pacific Region office

ProTrac Probate Case Management and Tracking System

QA Quality Assurance

QC Quality Control

RAF Recommended Action Forms

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

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]: Subgroup A contains Judgment IIM accounts with receipt deposit(s)
    and monthly interest postings through December 31, 2000, and no
    disbursement of funds. Subgroup B contains only Judgment IIM
    accounts with receipt deposit(s) and monthly interest postings with
    a single disbursement. Subgroup C contains only Judgment IIM
    accounts with receipt deposit(s) and monthly interest postings with
    multiple disbursements. Subgroup D contains accounts with both (1)
    Judgment transactions with receipt deposit(s) and monthly interest
    postings, and (2) land-based transactions (income from land
    interests owned by the account holder).

[^3]: Subgroup A contains Per Capita IIM accounts with receipt
    deposit(s) and monthly interest postings through December 31, 2000,
    and no disbursement of funds. Subgroup B contains only Per Capita
    IIM accounts with receipt deposit(s) and monthly interest postings
    with a single disbursement but do not necessarily disburse the
    entire balance of the account. Subgroup C contains only Per Capita
    IIM accounts with receipt deposit(s) and monthly interest postings
    with multiple disbursements but do not necessarily disburse the
    entire balance of the account. Subgroup D contains accounts with
    both (1) Per Capita transactions with receipt deposit(s) and monthly
    interest postings, and (2) land-based transactions (income from land
    interests owned by the account holder).

[^4]: Certain BIAM conversion items previously reported are not
    considered relevant to trust reform and have been omitted from this
    report.

[^5]: Reconciliation of the 1999 monthly program reports for one
    acquisition site resulted in an increase of 2,314 acquired
    fractionated interests that were less than 2% or the total tract.
    The reconciliation increases the cumulative total to 162,589
    (through May).