Treasury General Management and 

Infrastructure Support: 

Records Management at the 

Bureau of the Public Debt 

OIG-02-032 January 30, 2002

Office of Inspector General

******* 

The Department of the Treasury 
Contents 

Records Management at BPD (OIG-02-032) Page 1

Audit Report................................................................................................. 3 

 Results in Brief............................................................................................ 4 

 

 Background................................................................................................. 5 

 Findings and Recommendations..................................................................... 7 

Records Management Policies and Procedures ............................................ 7 

 Recommendations................................................................................... 8 

Records Management Program ................................................................ 9 

 Recommendation .................................................................................... 13 

 Records Schedules .................................................................................. 14 

 Recommendation .................................................................................... 15 

 Disposition of Records ............................................................................ 15 

 

Appendices

 Appendix 1: Objectives, Scope, and Methodology...................................... 19 

 Appendix 2 Management Comments ....................................................... 21 

 Appendix 3: Major Contributors To This Report ......................................... 22 

 Appendix 4: Report Distribution............................................................... 23 

Abbreviations 

AC Assistant Commissioner 

 BPD Bureau of the Public Debt 

 CFR Code of Federal Regulations 

 Department Department of the Treasury 

 DO Departmental Offices 

 ED Executive Director 

 FOIA Freedom of Information Act 

 FMS Financial Management Service 

 FRC Federal Records Center 
Contents 

Records Management at BPD (OIG-02-032) Page 2

Abbreviations (continued) 

 FY Fiscal Year 

 GPRB Graphics, Printing and Records Branch 

 GRS General Records Schedules 

 IIM Individual Indian Monies 

 NARA National Archives and Records Administration 

 OIG Office of Inspector General 

 OMB Office of Management and Budget 

 OPDA Office of Public Debt Accounting 

 PDI Public Debt Issuance 

 SBOO Savings Bond Operations Office 

 SF Standard Form 

 TD Treasury Directive 

 TD P Treasury Directive Publication 

 USC United States Code 
OIG Audit 

Report

The Department of the Treasury 

Office of Inspector General 

Records Management at BPD (OIG-02-032) Page 3

 January 30, 2002 

 Van Zeck 

 Commissioner 

Bureau of the Public Debt 

The Department of the Treasury (Department) manages records 

throughout their life cycle to facilitate accomplishment of the 

agency's programmatic and administrative missions, to preserve 

official agency records in accordance with statutory and regulatory 

requirements, and to ensure access to information by Treasury 

officials and the public, as appropriate. The Department plans and 

establishes a framework for managing and overseeing a 

comprehensive agency-wide records management program. All 

records of the Department should be listed, and accounted for, in 

records schedules, and their disposition should be in accordance 

with the schedules. 

The Federal Records Act requires agencies to create and preserve 

records containing adequate and proper documentation of their 

functions, policies, procedures, and essential transactions. The 

Federal Records Act also requires that agencies establish and 

maintain a program for the efficient management of their records 

and management programs. In addition, the Paperwork Reduction 

Act of 1995, with respect to records management, requires each 

agency to implement and enforce applicable policies and 

procedures, including requirements for archiving information 

maintained in electronic format, particularly in the planning, design, 

and operation of information systems. 

The objectives of the audit were to determine whether the Bureau 

of the Public Debt (BPD) had implemented applicable records 

management policies and procedures in accordance with regulatory 

guidance, and to evaluate whether BPD had controls that would 

allow for authorized, timely, and appropriate disposition of records. 
Records Management at BPD (OIG-02-032) Page 4 

In addressing the first objective, we also considered whether 

procedures regarding litigation activities would enable program 

staff to appropriately communicate the need for records 

information and to retrieve documents required for litigation and for 

Freedom of Information Act (FOIA) and congressional requests prior 

to disposition. With reference to litigation, it should be noted that 

the Department has been under Court Order to preserve all 

documents relating to the Individual Indian Monies (IIM) Trust 

Fund.1

As part of this multi-bureau review of controls over records 

management, we conducted audit work at Departmental Offices 

(DO), at the Financial Management Service (FMS), and at BPD from 

April 2000 to January 2001. This report reflects the results of our 

work at BPD. We plan to issue separate reports for DO and FMS. 

A more detailed description of our objectives, scope, and 

methodology is provided as Appendix 1. 

Results in Brief

We found that, at the time of our field work, BPD had taken action 

to improve its records management policies and procedures in 

accordance with regulatory and Treasury requirements. Over the 

years, BPD has also enhanced its records management program, by 

taking steps such as implementing an excellent automated records 

management system. 

Additional action has been taken or planned since we completed 

our work, as part of an ongoing effort to enhance the BPD records 

management program within the current operational environment. 

The actions taken or planned by BPD are reflected under each of 

the four Findings in this report. 

 

1

 Cobell, et al, v. Norton, Civ.No. 96-01285(RCL)(D.D.C.), addressing the Federal government’s 

management of the Individual Indian Monies Trust Fund (referred to as Cobell in this report). 
Records Management at BPD (OIG-02-032) Page 5 

Our report presents four recommendations to the Executive 

Director, Administrative Resources Center. BPD actions taken or 

planned address these recommendations. 

BPD provided a response to our final draft report. This response, 

dated January 29, 2002, is included as Appendix 2. 

Background 

When conducting business, every Federal agency creates a large 

number of records in a variety of media. Numerous laws, 

regulations, and directives have been formulated to address records 

management practices, including the following that apply to BPD. 

• The Federal Records Act, 44 United States Code 

(USC) 3105.

• The Paperwork Reduction Act of 1995, 44 USC 3506.

• The Freedom of Information Act, 5 USC 552. 

• Office of Management and Budget (OMB) Circular A-130, 

Management of Federal Information Resources, dated 

February 8, 1996. 

• National Archives and Records Administration (NARA) 

Regulations, 36 Code of Federal Regulations (CFR) 1220 

and following.

• NARA General Records Schedules.

• Treasury Directive (TD) 80-05, Records and Information 

Management Program, dated February 23, 2000.

• Treasury Directive Publication (TD P) 80-05, Records and 

Information Management Manual, issued during March 2000. 

• Records Management Self-Evaluation Guide, issued by 

NARA, revised/adopted by Treasury during August 1999. 

• Public Debt Issuance (PDI) 25-02, Records Management 

Program, issued on May 17, 1995, and last revised during 

September 1998. 

• PDI 106-01, Litigation Documents, issued on May 31, 2000. 
Records Management at BPD (OIG-02-032) Page 6 

BPD is responsible for borrowing the funds needed to operate the 

Federal Government and accounting for the resulting debt. BPD 

finances the nation’s debt through the sale of marketable securities 

(bills, notes, and bonds), special purpose securities, and 

nonmarketable United States Savings Bonds. BPD’s primary 

activities are marketing, issuing, servicing, and retiring public debt 

securities, and accounting for the public debt and related interest 

cost. 

Responsibility for administering BPD’s records management 

program resides with the Office of the Executive Director, 

Administrative Resources Center; specifically, within the Graphics, 

Printing and Records Branch (GPRB) under the Division of 

Administrative Services. The GPRB Records Officer’s 

responsibilities included: 

• Developing and implementing a program to identify, develop, 

issue, and review recordkeeping requirements regardless of 

form; 

• Issuing a Public Debt directive on the Records Management 

Program; 

• Establishing procedures for the participation of the program 

to assure compliance of records creation, maintenance, 

disposal, and evaluation; 

• Ensuring adequate training to Public Debt personnel on 

policies, responsibilities, and techniques; 

• Developing and implementing records schedules for all 

records created and received; and 

• Reviewing the Records Management Program periodically to 

evaluate the adequacy of documentation, maintenance, and 

disposition. 

Through the responsibilities listed above, the GPRB Records Officer 

has a liaison with the Department, with BPD’s Office of Chief 

Counsel, and with all of the BPD Assistant Commissioner (AC) and 

Executive Director (ED) offices. 
Records Management at BPD (OIG-02-032) Page 7 

Within the Office of the Commissioner and at each of the 

five AC and two ED offices, BPD has assigned designated Records 

Coordinators, secretarial staff, and management personnel the 

responsibilities for their respective records program activities and 

functions. This includes the BPD locations in Washington, D.C., 

and Parkersburg, West Virginia. 

Findings and Recommendations 

Finding 1 Records Management Policies and Procedures 

 

Overall, we concluded that BPD had taken actions to improve its 

records management policies and procedures in accordance with 

regulatory guidance and the Treasury Directives.2

 At the time of 

our onsite work, we found several minor omissions to references 

and authorities from the Treasury Directives. We also found that 

BPD had addressed records requirements when litigation is 

involved, but had not developed separate electronic recordkeeping 

policies and procedures. 

To communicate litigation-related retention requirements, BPD 

records management staff worked with BPD’s Office of Chief 

Counsel to issue PDI 106-01 during May 2000. This issuance 

established the responsibilities, policies, and procedures for 

preserving information required for litigation, including electronic 

records. Additionally, a cooperative working relationship with BPD 

Counsel offices in Washington and Parkersburg was established to 

ensure that current records potentially relevant to ongoing 

litigation, and any future records, are appropriately handled and 

accounted for. 

Further, BPD was using various methods, such as electronic 

messages, memorandums, meetings, and other reminders for 

employees, particularly the records management staff, on the 

 

2

 In this report, the term Treasury Directives is used to refer to TD 80-05 and TD P 80-05 collectively. 

In instances where a statement applies to only one of the two documents, the specific reference is 

shown. 
Records Management at BPD (OIG-02-032) Page 8 

importance of records preservation. Some of this communication 

described the administrative and criminal penalties for violation 

of regulatory requirements or unlawful disposal of records. 

One example is a September 1, 1999, memorandum that the 

Commissioner sent to all BPD employees on the importance of 

retaining documents and data that was potentially relevant to a 

specific lawsuit against the Department. BPD also has 

implemented a notice regarding the importance of retaining 

litigation-related records in its orientation for new employees. 

BPD records management staff told us that electronic records are 

handled in the same manner as all other documentary materials, as 

stated in an electronic message issued on February 19, 1998. The 

current policy on electronic mail is the same as that used by NARA, 

which is that if an electronic message is considered to be a record, 

it should be printed and filed in an existing recordkeeping system. 

At the time of our review, we felt that additional guidance should 

be provided for all records management staff to ensure that 

electronic records are properly maintained in accordance with 

regulatory requirements and with the Treasury Directives. This 

may be accomplished by revising PDI 25-02. 

Section 3102 of the Federal Records Act requires each agency to 

establish and maintain an active, continuing program for the 

economical and efficient management of records. Additionally, 

NARA issued General Records Schedule (GRS) Number 20, 

Electronic Records, during 1995 to provide disposal authorization 

for certain electronic records and specified hard-copy (paper) or 

microform records that are integrally related to the electronic 

records. 

Recommendations 

1. The Executive Director, Administrative Resources Center, 

should require the Director, Division of Administrative Services, 

to revise policies and procedures to incorporate references and 

authorities from the Treasury Directives (TD 80-05 and 
Records Management at BPD (OIG-02-032) Page 9 

TD P 80-05) to reflect any changes that have occurred since 

BPD’s last revisions were made during September 1998.

Management Response

Management stated that records management personnel were 

fully aware of the provisions of the Treasury Directives and 

operated in accordance with them, so that BPD’s records 

program was not weakened by the minor omissions presented 

in this Finding. Management plans to incorporate the references 

and authorities from the Treasury Directives into BPD policies by 

May 31, 2002. 

Office of Inspector General (OIG) Comments

The OIG believes that the action that BPD plans to take 

addresses the intent of the recommendation. 

2. The Executive Director, Administrative Resources Center, 

should require the Director, Division of Administrative Services, 

to revise records management procedures in the existing 

issuance, PDI 25-02, to provide electronic recordkeeping 

guidance. 

Management Response

Management plans to make revisions to PDI 25-02 to provide 

guidance on electronic recordkeeping by May 31, 2002. 

OIG Comments 

The OIG believes that the action that BPD plans to take 

addresses the intent of the recommendation. 

Finding 2 Records Management Program 

At the time of our review, we concluded that BPD had taken 

actions to improve its records management program, which for 
Records Management at BPD (OIG-02-032) Page 10 

the most part complied with regulatory requirements and the 

Treasury Directives. Actions included implementing a new 

automated records management system during 1994 and 

assigning Records Coordinators for all BPD offices for the last 

nine years. BPD continues to refine its records management 

program. 

In general terms, the Records Management Self-Evaluation Guide

states that an effective records management program includes 

clear definitions of objectives, responsibilities, and authorities; 

sufficient resources to administer the program; training and 

guidance for staff; and periodic internal program evaluations to 

monitor compliance and program efficiency. Section 3102 of the

Federal Records Act requires an agency to establish and maintain 

an active, continuing program for the economical and efficient 

management of its records. Moreover, OMB Circular A-130 states 

that records management programs should provide adequate and 

proper documentation of an agency’s activity, ensure the capability 

to access records regardless of form or medium, and provide 

training and guidance to program staff regarding their records 

management responsibilities. 

In our opinion, BPD’s automated records management system 

serves as an excellent records management model. It provides 

BPD employees with information on storage, retrieval, removal, 

and destruction of records. The system has the capability to track 

records and to generate reports as necessary regarding the status 

of records. Management controls were appropriately built into the 

system, which transmits destruction notices to offices when 

records on the automated records schedules have met their 

retention periods. In addition, controls are in place to require 

program managers to provide electronic approval to GPRB records 

specialists before records are removed, destroyed, or held. Beyond 

this required electronic approval, management advised us that 

additional procedures have been implemented within GPRB to 

identify and prevent the destruction of litigation-related records. 
Records Management at BPD (OIG-02-032) Page 11 

Discussed below are three areas for which we believed additional 

action was warranted at the time of our review, i.e., staffing 

levels, training and guidance programs, and internal program 

evaluations. Contributing reasons cited for lack of action in these 

three areas at that time were low priority given to records 

management initiatives by senior management and limited 

resources assigned to GPRB, until involvement in recent litigation. 

Staffing Levels

At the time of our review, GPRB had one Records Officer, one 

Records Specialist, and one Management Assistant, who functions 

as a records program analyst, to administer the BPD records 

program. Duties of this staff included maintaining the automated 

system and storage facilities, conducting training for the five AC 

and two ED areas, reviewing and coordinating records schedule 

revisions with NARA, scheduling new computer systems with 

NARA, coordinating and retrieving active and inactive records, and 

handling the storage and destruction notices. 

Also, GPRB staff had been tasked with assisting the Office of Chief 

Counsel and the designated AC and ED offices to assess the 

appropriateness of retention periods for records deemed relevant to 

specific litigation. At the time of our review, we felt that BPD 

should consider assigning additional resources to assist with 

records management functions. 

Training and Guidance Programs

 

At the time of our review, we felt that BPD should enhance 

its training and guidance program for its records management 

employees. BPD policies and procedures state that adequate 

training should be provided to personnel on policies, 

responsibilities, and techniques. Regulatory guidance and the 

Treasury Directives include similar requirements. 

Our analysis found that, for the most part, training had been limited 

to that provided by the BPD GPRB records staff. Also, outside 

training, when provided, had been limited to GPRB staff. At the 
Records Management at BPD (OIG-02-032) Page 12 

time of our review, the GPRB Records Officer, Records Specialist, 

and Management Assistant had had limited records management 

training within the last three years. For example, the Records 

Officer had last received records management training during 

1990, and the Management Assistant had last attended training 

during 1994. Thus, we felt that more training opportunities on 

government-wide and Treasury records management practices 

should be provided to GPRB staff and to BPD program staff who 

serve as Records Coordinators. 

Of the twelve program staff we interviewed, six (50 percent) 

had not received training on the regulations and the Treasury 

Directives. Three (25 percent) had received training from external 

sources, such as NARA, and three (25 percent) had received 

internal training, one in early 2000, one in 1999, and one in 1994. 

Among the six who had not attended training were two managers 

responsible for records management in their offices. In addition, 

GPRB staff members responsible for training others had received 

only limited training from external sources such as NARA. 

In general terms, the Records Management Self-Evaluation Guide

states that an effective management program requires the inclusion 

of timely and continuing training and guidance for program or 

records officers, and for others with regular records management 

duties. The guidance also requires that records management 

liaisons, secretaries, file clerks, and those program staff with 

regular records management duties receive guidance and training in 

records maintenance and filing procedures and records disposition. 

Internal Program Evaluations

Although GPRB completed an internal program evaluation of its 

records management operations during February 2000, no such 

evaluation had been performed in prior years. At the time of our 

review, the records specialist was assigned this responsibility and 

was performing internal reviews as time permitted. Limited 

staffing and other priorities, including the records duties discussed 

in the Staffing section above, were cited as the reasons for not 

completing program reviews in prior years. 
Records Management at BPD (OIG-02-032) Page 13 

Recommendation

3. The Executive Director, Administrative Resources Center, 

should require the Director, Division of Administrative Services, 

to continue efforts to implement an effective records 

management program that complies with regulatory 

requirements and with the Treasury Directives, by taking 

actions such as (a) evaluating the sufficiency of current 

resources, including staffing, (b) providing appropriate training 

and guidance; and (c) conducting internal program evaluations.

Management Response

BPD enhanced program staffing by adding a Records Specialist 

during April 2001. In addition to program officials, there are 

more than 40 Records Coordinators who are accountable for 

records management within each of the BPD offices, as part of 

a strong and broad-based program. 

During the last seven years, the Records Coordinators have 

been routinely exposed to records management responsibilities, 

and have received training on BPD’s records management 

system. All new employees are now briefed on records 

management as part of BPD’s orientation. During 2001, 

about 200 employees attended five different training sessions 

presented by a nationally respected vendor and targeted to staff 

involved in the records management process. 

BPD plans to continue to work to make its records management 

program better by incorporating its own improvements and 

suggestions from other entities. 

OIG Comments

The OIG believes that the actions taken and planned by BPD 

address the intent of the recommendation. 
Records Management at BPD (OIG-02-032) Page 14 

Finding 3 Records Schedules 

At the time of our field work, the Requests for Records Disposition 

Authority, Standard Forms (SF) 115, referred to as records 

schedules, were not current and needed revision. Records series 

had either been added or had become obsolete since SFs 115 had 

been updated, and a new electronic information system had been 

placed in use since NARA approved an office’s last SFs 115. 

Additionally, we found some offices had unscheduled records that 

were not included on the existing SFs 115. 

NARA, 36 CFR 1222.20, Agency responsibilities, states that each 

Federal agency shall review recordkeeping requirements, as part of 

the periodic information resources management reviews required 

by 44 USC 3506, or the periodic records-management evaluations 

required by 36 CFR 1220.54, in order to validate that they are 

current and to ensure that recordkeeping requirements are being 

implemented. Also, 36 CFR 1228.22, Developing records 

schedules, states that agencies should prepare an inventory of 

records, including a description of their medium, location, volume, 

inclusive dates, informational content, and use. Furthermore, 

36 CFR 1228.24, Formulation of agency records schedules, states 

that an SF 115 shall include only new records not covered by the 

GRS, deviations from the GRS, or previously scheduled records 

requiring changes in retention periods or substantive changes in 

description. 

TD 80-05 states that the bureau records management officers 

shall review all records schedules triennially to ensure that new 

categories of records are scheduled, that discontinued categories 

of records are eliminated, and that retention periods are altered 

where appropriate. In addition, TD 80-05 states that triennial 

reviews should be made to determine compliance with Federal 

records management regulations and also to provide the 

Department’s Records and Information Management Officer the 

required documentation to conduct reviews at a Departmental 

level. 
Records Management at BPD (OIG-02-032) Page 15 

We found that the SFs 115 for the offices that we reviewed 

needed revisions. The Office of Public Debt Accounting (OPDA), 

Federal Investment Branch, had seven records series that were 

undergoing SF 115 revisions, pending final review and a decision 

regarding retention periods. Some of the records series included 

trust fund records inherited by BPD when the trust fund functions 

were transferred from FMS in 1996. In addition, the BPD Records 

Specialist was reviewing the SF 115 updates for the OPDA Trust 

Funds Branch because records were not included in the existing 

SF 115. 

For the Savings Bond Operations Office (SBOO) Case Management 

Section we found that the Bureau Automated Tracking System, 

which had not been scheduled, had replaced an automated Case 

File Control System that was scheduled on the existing SF 115. 

We were told that the staff from the Case Management Section 

was working with BPD’s Records Specialist to ensure that this new 

system is scheduled. Also, the SF-115 for the SBOO Bond and 

Checking Processing Section was being revised because certain 

records needed to be added to the schedule or were obsolete since 

NARA approved the last SF 115. 

Recommendation

4. The Executive Director, Administrative Resources Center, 

should require the Director, Division of Administrative Services, 

to continue efforts to update the existing SFs 115 and/or 

prepare new SFs 115, and to conduct triennial reviews of the 

SFs 115. 

Management Response

A proposed revised records schedule was submitted to NARA 

on September 28, 2000, for Government Account Series, which 

includes Trust Fund records. As of January 28, 2002, NARA 

had not approved this records schedule. 
Records Management at BPD (OIG-02-032) Page 16 

BPD plans to continue its efforts to update the SF 115s and to 

conduct triennial reviews as required, with the first due to be 

completed by February 2003. 

OIG Comments

The OIG believes that the actions taken or planned by BPD 

address the intent of the recommendation. 

Finding 4 Disposition of Records

At the time of our review, BPD had on hand records that were 

scheduled for destruction onsite or at a Federal Records 

Center (FRC). Due to legal actions to preserve records after the 

scheduled dates, BPD had not carried out the destruction. We did 

not find any instances where BPD did not comply with its existing 

SFs 115 to remove inactive records from offices. BPD had been 

storing its inactive records at an off-site warehouse facility located 

in Parkersburg or at an FRC. Records that are scheduled for 

destruction but are retained beyond the scheduled dates may cause 

an agency to incur excessive storage costs. 

According to 36 CFR 1220.38, Disposition of records, agencies 

must ensure the proper, authorized disposition of their records 

regardless of format or medium, so that permanent records are 

preserved and temporary records no longer of use to an agency 

are promptly deleted or disposed of in accordance with approved 

records schedules when the required retention period expires. This 

section of the CFR also states that, as an intermediate step, when 

records are not needed for current day-to-day reference, they may 

be transferred to a records storage facility. BPD was following this 

approach, with offices maintaining active records (up to 2 years 

old) onsite, and sending inactive records (more than 2 years old) to 

BPD’s warehouse. 

BPD did not dispose of records according to the schedules due to 

several ongoing lawsuits filed against the Department. At the time 

of our review, there was a freeze on some of BPD’s records. 

However, offices were not disposing of records that were not 
Records Management at BPD (OIG-02-032) Page 17 

under the freeze. Thus, records that were not responsive to 

litigation were among those that remained at the warehouse. 

Until the scope of this freeze is narrowed, BPD litigation-related 

holdings will increase because new accessions will continue to be 

retired to the FRC system, but older accessions that are otherwise 

eligible for disposal will not be destroyed. Consequently, storage 

and service charges will increase. 

Also, if offices do not dispose of non-litigation records that should 

be destroyed, BPD will incur unnecessary charges. Subsequent 

destruction of records outside of the normal destruction period, 

depending on the timing, could also give the appearance of 

impropriety. 

During Fiscal Year (FY) 2000, NARA began charging agencies 

for storage and service costs for agency records maintained at its 

FRC facilities. Considering NARA and BPD warehouse costs, 

storage of BPD’s litigation-related records during FY 2001 cost 

about $5,300. While costs incurred by BPD and DO are relatively 

small when compared to those at FMS, the total amount for the 

Department was close to $400,000 for FY 2001. As more records 

reach the retention periods designated in the records schedules but 

are not destroyed, costs to the Treasury may escalate.

BPD management advised us that because BPD is operating under 

specific instructions to retain any and all documents that could 

possibly relate to the Cobell litigation, all other records retention 

issues, including possible costs, take on a secondary role. 

Management also advised us that BPD is currently disposing of 

records that have no possibility of containing IIM-related 

information. In addition, BPD has sought authority from the Court 

to dispose of records that are possibly IIM-related when the 

information is duplicated in other records or systems. For example, 

BPD sought, and the Court granted, specific authority to dispose of 

savings bonds applications under their normal retention schedules 

because primary records of purchases are being retained 

permanently. 
Records Management at BPD (OIG-02-032) Page 18 

While records retention costs are a concern when considered on 

a Treasury-wide basis, these costs will continue to be borne by the 

Department until such time as the Cobell case is adjudicated, or 

until the Court rules otherwise. Although NARA officials told us 

that some agencies are attempting to have the parties that have 

requested that records be retained; i.e., the Justice Department or, 

in some cases, the plaintiffs; pay the costs associated with storing 

records, this is not a course of action that Treasury plans to 

pursue. 

In this instance, then, BPD management feels there is every need 

for caution and deliberate action, and that the retention of some 

records past their scheduled disposition dates is to be expected, 

a position we respect. It is our understanding that once the 

constraints of litigation are lifted, Treasury management plans to 

resume the proper disposition of records on an ongoing, structured 

basis, in accordance with each office's records schedule. 

Because of the circumstances surrounding current litigation, we 

defer to the decisions of senior management at BPD regarding 

records retention, and make no further recommendations at this 

point. 

* * * * * * 

We would like to extend our appreciation to BPD for the 

cooperation and courtesies extended to our staff during the review. 

If you have any questions, please call me at (202) 927-6512 or 

Maria V. Carmona, Audit Manager, Banking and Fiscal Service, at 

(202) 927-6345. Major contributors to this report are listed in 

Appendix 3. 

Donald R. Kassel 

National Director, Banking and Fiscal Service 
Appendix 1 

Objectives, Scope, and Methodology 

Records Management at BPD (OIG-02-032) Page 19 

The objectives of the audit were to determine whether BPD had 

implemented applicable records management policies and 

procedures in accordance with regulatory guidance, and to evaluate 

whether BPD had controls in place that would allow for authorized, 

timely, and appropriate disposition of records. In addressing the 

first objective, we also considered whether procedures regarding 

litigation activities would enable program staff to appropriately 

communicate the need for records information and to retrieve 

documents required for litigation and for FOIA and congressional 

requests prior to disposition. 

Our audit work focused on the Office of the ED, Administrative 

Resources Center, which has primary responsibility for records 

management activities, and on selected Branches and Sections 

within the Offices of the ACs for OPDA and for SBOO. 

We obtained documentation during our entrance conference and in 

numerous interviews with key program staff, including records 

management officers, records specialists, managers, and others. 

We reviewed and evaluated the applicable records management 

policies and procedures at BPD using a checklist developed for that 

purpose. We also evaluated the controls implemented in BPD’s 

records management system designed to ensure authorized, timely, 

and appropriate disposition of records. We also conducted 

inventory assessments at selected program offices. 

This review was not part of the OIG Annual Plan for FY 2000, 

but rather was initiated, in part, based on the results of prior audit 

work3

 and in response to concerns raised about the disposal of 

historical records during pending litigation. Also, the Department’s 

Office of General Counsel had expressed interest in this matter. 

As part of this multi-bureau review of controls over records 

management, we conducted audit work at DO, at FMS, and at 

BPD’s Washington, D.C., and Parkersburg, West Virginia, locations. 

 

3

 Report titled Financial Management Service’s Deposit Fund Accounts Used for the Implementation of 

the Competitive Equality Banking Act, OIG-00-088, issued on May 30, 2000. 
Appendix 1 

Objectives, Scope, and Methodology 

Records Management at BPD (OIG-02-032) Page 20 

This report reflects the results of our work at BPD. We plan to 

issue separate reports for DO and FMS. 

We started our field work during April 2000 and completed onsite 

work at the three organizations during January 2001. We 

conducted our audit in accordance with generally accepted 

government auditing standards. 
Appendix 2 

Management Comments 

Records Management at BPD (OIG-02-032) Page 21 
Appendix 3 

Major Contributors To This Report 

Records Management at BPD (OIG-02-032) Page 22 

 Washington Headquarters

Donald R. Kassel, National Director, Banking and Fiscal Service 

 Maria V. Carmona, Audit Manager 

 C. Samuel McGeorge, Audit Manager 

 Ethel Taylor-Young, Auditor-in-Charge 

 Delores V. Dabney, Senior Auditor 
Appendix 4 

Report Distribution 

Records Management at BPD (OIG-02-032) Page 23 

 Department of the Treasury

 Office General Counsel 

 Office of Strategic Planning and Evaluations 

 Office of Accounting and Internal Control 

 Office of Budget 

 Bureau of the Public Debt

 Commissioner 

 Office of Chief Counsel 

 Assistant Commissioner, SBOO 

Assistant Commissioner, OPDA 

 Director, Administrative Resources Center 

Audit Liaison 

 Office of Management and Budget

 

 OIG Budget Examiner