Federal Housing Finance Agency 

Office of Inspector General

FHFA Needs to Strengthen Controls 

Over its Records Management 

Program to Comply with OMB and 

NARA Requirements 

Audit Report • AUD-2020-008 • March 26, 2020
AUD-2020-008

March 26, 2020

Executive Summary

The Housing and Economic Recovery Act of 2008 created and charged the 

Federal Housing Finance Agency (FHFA) with the supervision of Fannie Mae 

and Freddie Mac (together, the Enterprises), the Federal Home Loan Banks 

(collectively, the regulated entities), and the FHLBanks’ fiscal agent, the 

Office of Finance. Since 2008, FHFA has also served as conservator of the 

Enterprises.

The National Archives and Records Administration (NARA) is responsible 

for overseeing and setting standards for Federal agencies’ records 

management programs and practices. In a joint directive issued in August 

2012, the Office of Management and Budget (OMB) and NARA established 

two electronic records management goals applicable to all Federal agencies.

These goals were reaffirmed in June 2019. Goal 1 required electronic 

recordkeeping to ensure transparency, efficiency, and accountability, and 

management of electronic permanent records and of email records. Goal 2 

directed effective management of records consistent with Federal statutes and 

regulations and professional standards, and required employee training on 

records management and “scheduling” of records to ensure their proper 

retention and disposition. 

FHFA’s Records and Information Management (RIM) section within the 

Office of Technology and Information Management is responsible for the 

development, implementation, and management of FHFA’s records and 

information management program. According to FHFA, an essential 

component of its records and information management program is the “file 

plan,” a document that lists the official records (whether electronic or paper) 

in each FHFA division or office, their location, and their disposition 

(temporary or permanent).

We performed this audit to determine if FHFA achieved the records 

management goals established by OMB and NARA. The scope of our audit, 

however, did not include Goal 1.2 for managing email records. 

We found shortcomings with FHFA’s efforts to meet Goal 1 for managing 

permanent electronic records in an electronic format. For the 28 permanent 

electronic records in our sample, FHFA was unable to readily and reliably 

locate any of them, based on the location identified in its file plans. We did 

find 19 of these 28 permanent electronic records in locations other than those 

identified in FHFA’s file plans, before stopping our search. 

We also found that the records management training required of FHFA fell 

short in four areas. FHFA did not: 
AUD-2020-008

March 26, 2020

• Include all NARA-required training content topics in its 2019 annual 

records management training; 

• Show that all employees and contractor employees completed the 2019

refresher training; 

• Demonstrate that its new hire contractor employees completed the 

mandatory records management training when onboarding; and

• Establish that 5 of the 11 senior officials who offboarded during the 

review period for this test (January 1, 2019, to November 30, 2019) 

received mandatory records management training.

Our audit also found that FHFA was unable to demonstrate that all of its 

records were scheduled, as required by OMB and NARA.

We make four recommendations to address the identified shortcomings. In a 

written management response, FHFA agreed with our recommendations. 

This report was prepared by Tara Lewis, Audit Director; Terese Blanchard, 

Auditor-in-Charge; Brian Maloney, Auditor; and Pamela L. Williams, 

Auditor; and with assistance from Bob Taylor, Senior Advisor. We appreciate 

the cooperation of FHFA staff, as well as the assistance of all those who 

contributed to the preparation of this report. 

This report has been distributed to Congress, the Office of Management and 

Budget, and others and will be posted on our website, www.fhfaoig.gov, and 

www.oversight.gov. 

Marla A. Freedman, Deputy Inspector General for Audits /s/
OIG • AUD-2020-008 • March 26, 2020 4

TABLE OF CONTENTS ................................................................ 

EXECUTIVE SUMMARY .............................................................................................................2

ABBREVIATIONS .........................................................................................................................6

BACKGROUND .............................................................................................................................7

The National Archives and Records Administration Oversees Federal Agency 

Records Programs.....................................................................................................................7

Directive Jointly Issued by OMB and NARA in August 2012 Established Records 

Management Goals and Implementation Due Dates for Federal Agency Compliance ............8

Goal 1: Require Electronic Recordkeeping to Ensure Transparency, Efficiency, 

and Accountability ............................................................................................................9

Goal 2: Demonstrate Compliance with Federal Records Management Statutes 

and Regulations .................................................................................................................9

FHFA’s Records and Information Management Program ......................................................10

FHFA’s Office and Division File Plans ..........................................................................10

FACTS AND ANALYSIS .............................................................................................................11

FHFA Was Unable to Readily and Reliably Locate Permanent Electronic Records 

and Therefore Has Not Demonstrated Compliance with M-12-18, Goal 1.1 .........................11

FHFA Complied with Federal Records Management Statutes and Regulations Except 

for those on Training (Goal 2.4) and Records Schedules (Goal 2.5) .....................................12

Goal 2.4: Establish Records Management Training .......................................................13

Goal 2.5: The SAO Shall Ensure that Records Were Scheduled ....................................15

FINDINGS .....................................................................................................................................16

FHFA Could Not Readily and Reliably Locate Permanent Electronic Records in 

Accordance with its File Plans ...............................................................................................16

FHFA Fell Short in Complying with OMB and NARA Records Management 

Training Requirements ...........................................................................................................17

CONCLUSION ..............................................................................................................................18

RECOMMENDATIONS ...............................................................................................................18

FHFA COMMENTS AND OIG RESPONSE ...............................................................................19
OIG • AUD-2020-008 • March 26, 2020 5

OBJECTIVE, SCOPE, AND METHODOLOGY .........................................................................20

APPENDIX A: FHFA’S 28 PERMANENT ELECTRONIC RECORDS SELECTED 

FOR RETRIEVAL BY OIG ..........................................................................................................23

APPENDIX B: FHFA MANAGEMENT RESPONSE .................................................................24

ADDITIONAL INFORMATION AND COPIES .........................................................................27
OIG • AUD-2020-008 • March 26, 2020 6

ABBREVIATIONS ....................................................................... 

CRS Comprehensive Records Schedule

Enterprises Fannie Mae and Freddie Mac

FHFA Federal Housing Finance Agency 

GRS General Records Schedule

M-12-18 Managing Government Records Directive

M-19-21 Transition to Electronic Records 

NARA National Archives and Records Administration

OHRM Office of Human Resources Management 

OMB Office of Management and Budget 

RIM Records and Information Management 

SAO Senior Agency Official
OIG • AUD-2020-008 • March 26, 2020 7

BACKGROUND .......................................................................... 

The National Archives and Records Administration Oversees Federal Agency Records 

Programs

NARA is responsible for overseeing Federal agencies’ adequacy of documentation and 

records disposition programs and practices.1 NARA establishes standards for the retention of 

records having continuing value (permanent records) and assists Federal agencies in applying 

the standards to records in their custody. Through a record scheduling and appraisal process, 

NARA determines which Federal records have temporary value and may be destroyed and 

which Federal records have permanent value and must be preserved and transferred to the 

National Archives of the United States. NARA’s determination constitutes mandatory 

authority for the final disposition of all Federal records.

The following terms, as defined by NARA, provide key information regarding records 

management: 

• Record. A record includes recorded information, made or received by a Federal 

agency under Federal law or in connection with the transaction of public business. 

A record also includes information preserved by an agency as evidence of the 

organization, functions, policies, decisions, procedures, operations, or other activities 

of the United States Government. Recorded information includes all traditional forms 

of records, regardless of physical characteristics, including information created, 

manipulated, communicated, or stored in digital or electronic form.

• Records Management. Records management includes planning, controlling, 

directing, organizing, training, promoting, and other managerial activities related to 

the creation, maintenance and use, and disposition of records. Records management 

must be carried out to achieve adequate and proper documentation of Federal policies 

and transactions and effective and economical management of agency operations. 

• Records Lifecycle. The lifecycle of a record has three stages: (1) receipt and/or 

creation; (2) use and maintenance (including storing and retrieving records); and 

(3) disposition, which includes either transferring records to NARA for preservation 

or destroying the records. 

1 See 36 C.F.R. § 1220.10.
OIG • AUD-2020-008 • March 26, 2020 8

• Records Schedule. A records schedule provides specific, mandatory instructions for 

records no longer needed for current government business.2 Specifically, through the 

process of scheduling records, which includes determining the appropriate retention 

period and ultimate disposition of records, a records schedule is developed. NARA 

requires that Federal records be scheduled so that by the end of the records lifecycle 

they are handled correctly – either destroyed at the specified time or transferred to 

NARA for permanent preservation.

NARA issues General Records Schedules (GRS) to provide disposition authority for records 

common to agencies of the Federal Government (e.g., financial, human resource, technology, 

information management, general operations support, and mission support). All Federal 

records, in all formats, must be covered by a GRS or an agency specific, NARA-approved, 

records schedule.

Directive Jointly Issued by OMB and NARA in August 2012 Established Records 

Management Goals and Implementation Due Dates for Federal Agency Compliance

In response to a November 2011 Presidential Memorandum to begin an Executive Branchwide effort to reform records management policies and transition from paper records to 

electronic records where feasible,3 OMB and NARA jointly issued OMB Memorandum 

M-12-18, Managing Government Records Directive (M-12-18),4 on August 24, 2012. The 

expected benefits of this effort to “reform records management policies and practices” and 

“develop a 21st- century framework for the management of Government records” include: 

• Improved performance and promotion of openness and accountability by better 

documenting agency actions and decisions; 

• Further identification and transfer to NARA of the permanently valuable historical 

records through which future generations will understand and learn from our actions 

and decisions; and 

• Assistance to executive departments and agencies in minimizing costs and operating 

more efficiently.

2 NARA’s records control schedule repository provides Federal agencies and the public with open access to a 

large body of unclassified, NARA-approved records schedules (online here).

3 The White House, Presidential Memorandum—Managing Government Records (Nov. 28, 2011) (online 

here). 

4 See M-12-18 online here. 
OIG • AUD-2020-008 • March 26, 2020 9

M-12-18 established two goals and seven sub-goals applicable to all Federal agencies:

Goal 1: Require Electronic Recordkeeping to Ensure Transparency, Efficiency, and 

Accountability

Goal 1.1 By December 31, 2019, Federal agencies were to manage all permanent electronic 

records5 in an electronic format to the fullest extent possible for eventual transfer and 

accessioning6 by NARA. 

Goal 1.2 By December 31, 2016, Federal agencies were to manage both permanent and 

temporary7 email records in an accessible electronic format.

Goal 2: Demonstrate Compliance with Federal Records Management Statutes and 

Regulations

Goal 2.1 Agencies must designate a Senior Agency Official (SAO) with broad agency-wide 

responsibilities with respect to records management.

Goal 2.2 The SAO shall ensure that permanent records in existence for more than 30 years are 

identified for transfer and reported to NARA.

Goal 2.3 Agency Records Officers must obtain NARA Certificate of Federal Records 

Management Training.

Goal 2.4 Agencies must establish records management training8 to inform all employees of 

their records management responsibilities in law and policy.

5 According to NARA: (1) permanent records are “any Federal record that has been determined by NARA to 

have sufficient value to warrant its preservation in the National Archives of the United States, even while it 

remains in agency custody”; and (2) electronic records are “any information that is recorded in a form that only 

a computer can process and that satisfies the definition of a Federal record under the Federal Records Act.”

6 According to NARA, accession is defined as the act and procedures involved in a transfer of legal title and 

the taking of records into the physical custody of NARA.

7 According to NARA, temporary records are records approved by NARA for disposal after a specified 

retention period.

8 36 C.F.R. § 1220.34(f) requires agencies to provide guidance and training to all agency personnel on their 

records management responsibilities, including identification of Federal records, in all formats and media. 

NARA Bulletin 2017-01, Agency Records Management Training Requirements, provides the minimum 

required content areas for annual records management training (online here).
OIG • AUD-2020-008 • March 26, 2020 10

Goal 2.5 The SAO shall ensure that records are scheduled.9

Additionally, as required by M-12-18, the SAO is to report annually to NARA on agency 

progress in meeting the goals as well as on other significant records and information 

management initiatives as defined by NARA. FHFA began its annual reporting to NARA 

in 2013. 

Later, on June 28, 2019, OMB and NARA jointly issued OMB Memorandum M-19-21, 

Transition to Electronic Records (M-21-19).10 M-19-21 consolidated the requirements 

from M-12-18 and those in OMB Memorandum M-14-16, Guidance on Managing Email. 

According to NARA, M-19-21 represented a logical progression from the goals established 

in M-12-18. M-19-21 incorporated the seven goals from M-12-18 and builds upon them 

with more objectives intended to further move the Executive Branch to all-electronic 

recordkeeping. 

FHFA’s Records and Information Management Program

FHFA’s Records and Information Management Policy requires that Agency records be 

managed effectively throughout their lifecycle to facilitate and document the accomplishment 

of FHFA’s mission and function. Further, this policy states that effective management of 

FHFA records serves to preserve FHFA records in accordance with applicable statutory and 

regulatory requirements and to promote access to information by FHFA employees, FHFA 

partners, and the public, as appropriate. The policy applies to all FHFA employees and 

contractor employees.

FHFA’s Office and Division File Plans

The Records and Information Management Policy defines a file plan as a document that lists 

the official records in each FHFA division or office for which that division or office has 

custodial responsibility. According to FHFA, a file plan should include: record type (e.g., 

Annual Report to Congress, Targeted Examination Conclusion Letter, etc.); location; medium 

(i.e., paper or electronic); and a reference/link to a category of records identified in either the 

NARA-approved FHFA Comprehensive Records Schedule (CRS) or a NARA GRS; and 

disposition authority (which contains actions taken when records are no longer needed, 

either destroying or deleting the record when all relevant business needs have expired, or 

transferring the record to NARA for preservation). FHFA expects that the file plan will: 

(1) document activities effectively; (2) identify records consistently; (3) retrieve records 

9 36 C.F.R. § 1224.10 requires, among several things, Federal agencies to ensure Federal records are scheduled

and those schedules are regularly reviewed and updated as needed.

10 See M-19-21 online here. 
OIG • AUD-2020-008 • March 26, 2020 11

quickly; (4) implement disposition for records no longer needed; and (5) help the Agency 

meet regulatory requirements. According to FHFA’s Annual File Plan Review procedures, to 

keep file plans current, they are reviewed annually by the records liaison, division or office 

heads, and the RIM office to ensure that records they create and maintain are properly 

scheduled. 

FACTS AND ANALYSIS ............................................................... 

We performed this audit to determine whether FHFA achieved, by December 31, 2019, the 

records management goals established by OMB and NARA in M-12-18, and incorporated into 

M-19-21, except for Goal 1.2, the goal established for management of email records.

FHFA Was Unable to Readily and Reliably Locate Permanent Electronic Records and 

Therefore Has Not Demonstrated Compliance with M-12-18, Goal 1.1 

Goal 1.1 requires Federal agencies, by December 31, 2019, to manage all permanent 

electronic records in an electronic format, to the fullest extent possible, for eventual transfer 

and accessioning by NARA. According to RIM officials, all of FHFA’s permanent electronic 

records were housed on one of four network server drives or on other supervision and housing 

mission electronic systems.11 These officials explained that the location of FHFA’s permanent 

electronic records should be able to be identified through the file plan associated with each 

FHFA division and office. In 2019, FHFA had 15 division/office file plans. 

During our audit, we selected 28 permanent electronic records from the file plans prepared 

and maintained by seven FHFA divisions and offices.12 Using the location for each of the 28 

permanent electronic records in the file plans, we sought to retrieve each of the 28 permanent 

electronic records.

None of the 28 selected permanent electronic records could be retrieved using the location 

identified in FHFA’s file plans. For example, according to FHFA’s Office of Budget and 

11 During the field work for this audit, FHFA repeatedly stated, and confirmed in writing, that the universe of 

electronic systems for its supervision and housing mission work consisted of four systems. However, FHFA, in 

a March 9, 2020, technical comment to this draft, maintained for the first time that it could have more than the 

four previously identified systems. For purposes of this audit, we consider that the electronic systems for 

FHFA’s supervision and housing mission include: Public Use Database, National Mortgage Database, House 

Price Index, and Mortgage Loan Integrated System.

12 Using FHFA’s 2019 file plans, we selected 28 permanent electronic records that were either mission-related

or were created in support of the Agency’s mission and have historical significance. See Appendix A for a 

complete list of the 28 permanent electronic records selected for this test.
OIG • AUD-2020-008 • March 26, 2020 12

Financial Management’s file plan, the Agency’s Annual Performance and Accountability 

Report13 was located in a folder titled CRS “item 1.2 Official Agency Communications, 

Congressional Relations, and Publications.” However, we found no such folder. We 

eventually located the permanent electronic record in a folder titled “CRS item 6.1a Project 

Files.” This folder was intended to house only temporary electronic records, according to the 

file plan. That erroneous storage of this document is significant because temporary records 

are managed with a retention period of 15 years, after which the record may be deleted or 

destroyed. 

We were eventually able to locate 19 of the 28 selected records; of these, 12 records 

were located through our own search of FHFA’s systems, and 7 records were located with 

assistance from FHFA officials. Because the search for the 28 records was so time-consuming 

and cumbersome, we stopped our search for the remaining 9 records.14

RIM officials acknowledged weaknesses with the existing file plans, based on our testing 

of the file plans for the 28 records, and the need for RIM to work with each division or office 

to revise its file plans to include the actual file path for each record type to reflect better 

identification of the location of each record. However, in its March 9, 2020, technical 

comments to a draft of this report, FHFA appeared to claim that the timeliness, or lack 

thereof, of electronic records retrieval does not run afoul of the NARA and OMB 

requirements. According to FHFA, it was sufficient under its Records and Information 

Management Policy for subject matter experts in each division or office to have knowledge of 

the location of each permanent electronic record for retrieval purposes. 

We do not agree with FHFA’s position. The purpose of electronic management of permanent 

electronic records is to facilitate the identification and location of such records within a 

Federal agency, both to increase internal efficiencies and to facilitate the transfer to NARA 

of permanent records without reliance on subject matter experts who will change over time.

FHFA Complied with Federal Records Management Statutes and Regulations Except 

for those on Training (Goal 2.4) and Records Schedules (Goal 2.5)

According to M-12-18, the Federal Government should commit to manage more effectively 

all records consistent with Federal statutes and regulations. To achieve this goal, M-12-18 

13 The Performance and Accountability Report provides the financial statements and analysis for FHFA, and it 

assesses the performance of FHFA as regulator of the FHLBank System and as regulator and conservator of 

the Enterprises.

14 During our efforts to retrieve permanent electronic records, we identified one file plan that was incomplete. 

FHFA’s Division of Housing Mission and Goals is, among other things, responsible for managing data sets 

contained in FHFA’s House Price Index (a broad measure of the movement of single-family house prices). 

However, this record type along with its location was not identified in the Division’s 2019 file plan.
OIG • AUD-2020-008 • March 26, 2020 13

states that agencies must meet five requirements: (1) designate an SAO for records 

management (Goal 2.1); (2) ensure that permanent records are identified for transfer to 

NARA (Goal 2.2); (3) obtain NARA Certificates of Federal Records Management Training 

for Records Officers (Goal 2.3); (4) establish records management training (Goal 2.4); and 

(5) the SAO should ensure that records are scheduled (Goal 2.5). 

We found that FHFA demonstrated compliance with Goal 2.1, Goal 2.2, and Goal 2.3. We 

found shortcomings with FHFA’s efforts to comply with Goals 2.4 and 2.5. 

Goal 2.4: Establish Records Management Training

According to M-12-18 and NARA Bulletin 2017-01, Agency Records Management Training 

Requirements, Federal agencies are required to establish and provide training to all agency 

personnel on their records management responsibilities, including employees, contractor 

employees, volunteers, and others who create, receive, or use Federal records on behalf of the 

Agency. NARA Bulletin 2017-01 outlines the following requirements for agency records 

management training: 

• All employees and contractor employees with email or information technology 

network access must complete annual records management training that includes 15 

required topics; 

• All new hire employees and contractor employees with email or information 

technology network access must complete records management training upon 

onboarding; and 

• All political appointees, senior agency officials, and senior executives must be 

provided with targeted records management training upon onboarding and prior to 

departure.

To assess the requirements set forth in M-12-18 and NARA Bulletin 2017-01, we performed 

the following tests to determine if FHFA established and provided its records management 

training programs in 2019. 

Annual Records Management Training

We performed three tests of FHFA compliance with the annual records management training 

requirement:

• We reviewed the content in FHFA’s 2019 annual records management training 

materials to determine whether FHFA incorporated all 15 required content topics 

in NARA Bulletin 2017-01. We found that two required topics were not included: 

(1) the difference between temporary and permanent records; and (2) what to do when 
OIG • AUD-2020-008 • March 26, 2020 14

records are removed, lost, or destroyed without proper authorization. FHFA officials 

asserted that these topics were covered in the training materials but were unable to 

show us where. 

• We sought to determine whether all FHFA employees and contractor employees 

completed the 2019 annual records management training. FHFA’s 2019 annual 

records management training was made available to employees and contractor 

employees through FHFA’s internal newsletter and intranet. We found that FHFA 

was not able to demonstrate that its personnel (totaling approximately 600 Federal 

employees and an unknown number of contractor employees) completed the 2019 

annual records management training. While FHFA “pushed out” the availability of its 

2019 annual refresher training materials, it did not direct employees and contractor 

employees to review the materials and did not track those who did or did not review 

the training materials.

• We interviewed eight FHFA employees to determine if they were aware of their 

responsibilities for managing records on behalf of FHFA.

15 We found that the 

employees understood some but not all of their responsibilities for managing records. 

For example, six of the eight employees we interviewed said they did not know how 

and/or when to declare a record.

Records Management Training for New Hires

We sought to determine whether new hire employees16 completed required records 

management training by comparing the names of employees who onboarded between 

January 1, 2019, and November 30, 2019, to FHFA’s training records. We found that all 

61 new hire employees who onboarded during this period completed the training.

We sought to perform the same test for contractor employees. After multiple requests, 

FHFA was not able to provide us with a complete list of new hire contractor employees.17

15 Using FHFA’s 2019 organizational chart and a listing of records liaisons, we selected the eight individuals 

based on the office they worked in (mission related) and the likelihood that the individuals would handle

permanent electronic records in the performance of their work. 

16 This test excludes FHFA employees who are political appointees, senior agency officials, or senior 

executives, as these employees are required to take targeted records management training upon onboarding.

17 In a prior audit, we found that FHFA was unable to provide an accurate count of departed contractor 

employees. By not having an accurate record of contractor personnel who departed, we found that FHFA 

cannot be assured that access to its facilities is limited to authorized personnel, all assets are accounted for, and 

agency information is secure. See FHFA’s Offboarding Controls over Access, Cards, Sensitive IT Assets, and 

Records Were Not Always Documented or Followed During 2016 and 2017 (Mar. 13, 2019) (AUD-2019-004) 

(online here). As of the date of this report, the recommendation related to this finding remains open.
OIG • AUD-2020-008 • March 26, 2020 15

Accordingly, FHFA was not able to demonstrate that its new hire contractor employees 

completed the required training. 

Targeted Records Management Training for Senior Officials

We sought to determine whether FHFA provided targeted records management training to 

all senior officials (political appointees, senior agency officials, and senior executives) who 

onboarded between January 1, 2019, and November 30, 2019. We found that all 14 senior 

officials who onboarded during that period completed the training. 

Regarding the senior officials who offboarded between January 1, 2019, and November 30, 

2019, we sought to determine whether FHFA provided targeted records management training 

to all senior officials prior to departure. FHFA could not provide documentation that 5 of the 

11 senior officials who offboarded during that period received the required targeted records 

management training. 

With respect to training, we found that RIM’s internal procedures for records management 

did not include guidance on the content, timing, and documentation for records management 

training.18

Goal 2.5: The SAO Shall Ensure that Records Were Scheduled

Goal 2.5 requires that Federal agencies ensure that all Federal records are scheduled. As 

previously discussed, scheduling a record involves determining and recording, in a records 

schedule, the appropriate retention period and ultimate disposition of a series of records.19

FHFA reported to NARA in 2015 and 201620 that it was in compliance with this goal in that 

all Agency records were covered either by its CRS or NARA’s GRS. FHFA also reported that 

during its annual file planning process, business units are evaluated to ensure that records they 

create and maintain are properly scheduled. 

We performed two tests to determine whether FHFA could demonstrate all Agency records 

were scheduled. First, we sought to determine whether FHFA’s CRS was approved by NARA 

18 The only mention of training was in FHFA’s Annual File Plan Review procedures, which state: “RIM team 

members are responsible for ... providing front-line records management services and training to agency staff 

and contractor personnel.”

19 According to NARA, a record series is a group of records arranged according to a filing system or kept 

together because they relate to a particular subject or function, result from the same activity, document a 

specific type of transaction, exist in the same media format, or have some other type of relationship.

20 NARA did not ask questions related to compliance with Goal 2.5 for the 2017 and 2018 annual report.
OIG • AUD-2020-008 • March 26, 2020 16

and found that NARA approved the CRS on January 11, 2013, and then again on October 23, 

2014, after FHFA had amended its CRS. 

Second, we sought to determine whether records that FHFA identified in its 15 division/office 

file plans for 2019 were linked to a records schedule – either FHFA’s CRS or NARA’s GRS.

We found that 14 of the 15 file plans contained records that were scheduled. The remaining 

file plan, for Office of Human Resource Management (OHRM), contained 20 types of records 

that had no link to FHFA’s records schedule or to NARA’s GRS. Accordingly, FHFA was not 

able to demonstrate that these records were scheduled.21 The records in OHRM had no link to 

a records schedule in the following categories: personnel security; benefits; and operations 

and program management (which includes classification, compensation, payroll, performance 

management, recruitment, and staffing). RIM officials acknowledged the OHRM file plan had 

missing links to a records schedule. 

FINDINGS ................................................................................. 

FHFA Could Not Readily and Reliably Locate Permanent Electronic Records in 

Accordance with its File Plans

By December 31, 2019, FHFA was to manage all permanent electronic records in an electronic 

format, to the fullest extent possible, for eventual transfer and accessioning by NARA.

According to FHFA’s Records and Information Management Policy, a file plan is the document 

that, among other things, lists the official records in each FHFA division or office for which that 

division or office has custodial responsibility and identifies the location of those records to 

facilitate their retrieval and disposition. However, none of the 28 permanent electronic records 

we tested in February 2020 were in the locations specified in FHFA’s file plans. While we 

eventually found 19 of the permanent electronic records in locations other than where FHFA’s 

file plan identified them to be, the search was arduous and time-consuming. We also found that 

one permanent electronic record was erroneously stored in a location tagged for temporary 

records, where it could have been deleted or destroyed after 15 years.

21 In its March 9, 2020, technical comments to a draft of this report, FHFA maintained that all Federal agencies 

must adhere to NARA’s GRS for Human Resources so FHFA’s Human Resources records, which are covered 

by the NARA GRS and OMB regulation, are scheduled. The existence of a regulatory requirement, by itself, 

does not mean that every Federal agency is in compliance with that requirement. We agree with FHFA that its

Human Resources records are covered by the NARA GRS. However, we found that the file plan for OHRM 

contained 20 types of records that had no link to FHFA’s records schedule or to NARA’s GRS. The absence of 

a link to a records schedule does not support an assumption that those records are covered by NARA’s GRS. 
OIG • AUD-2020-008 • March 26, 2020 17

FHFA Fell Short in Complying with OMB and NARA Records Management Training 

Requirements

FHFA did not fully meet or could not demonstrate that it met all requirements for records 

management training. Specifically:

• FHFA’s 2019 annual records management training materials did not include two 

NARA-required content topics: (1) the difference between temporary and permanent 

records, and (2) what to do when records are removed, lost, or destroyed without 

proper authorization. Accordingly, FHFA employees and contractor employees may 

not fully be aware of or understand their records management responsibilities. 

• Federal agencies are required to provide annual refresher training to all applicable 

agency personnel on their records management responsibilities. While FHFA “pushed 

out” the availability of its 2019 annual refresher training materials on its internal 

employee website and through a newsletter, it did not direct employees and contractor 

employees to review the materials and did not track those who did or did not review 

the training materials.

• Federal agencies are required to establish and provide training to all applicable 

new hire employees and contractor employees on their records management 

responsibilities. FHFA was unable to provide a list of onboarded contractor employees 

between January 1, 2019, and November 30, 2019. Accordingly, FHFA was not able 

to demonstrate that all new hire contractor employees completed the required training.

FHFA’s inability to account for contractor employees was also a finding in a prior 

OIG audit related to FHFA’s offboarding process.22 FHFA agreed with our 

recommendation in that report to implement controls ensuring all departed contractor 

employees complete applicable offboarding requirements. As of the date of this report, 

that recommendation remains open. 

• Federal agencies are required to establish and provide targeted training to 

all onboarding and offboarding senior officials of their records management 

responsibilities. While we found that all senior officials who onboarded between 

January 1, 2019, and November 30, 2019, completed the required targeted training, 

FHFA could not provide documentation that all senior officials who offboarded during 

that period completed the required targeted training. 

22 OIG, FHFA’s Offboarding Controls over Access Cards, Sensitive IT Assets, and Records Were Not Always 

Documented or Followed During 2016 and 2017 (Mar. 13, 2019) (AUD-2019-004) (online here).
OIG • AUD-2020-008 • March 26, 2020 18

RIM’s internal procedures for records management did not include guidance on the content, 

timing, and documentation for records management training. 

FHFA Could Not Demonstrate that All Records Were Scheduled

Federal agencies must ensure that all Federal records are scheduled. We found that FHFA’s 

file plan for one division contained 20 types of records that had no link to a NARA-approved 

records schedule.

CONCLUSION ............................................................................ 

The August 2012 OMB and NARA joint directive on managing Federal government records 

set forth specific goals for agencies. FHFA has work to do to be in compliance with the joint 

directive. None of the permanent electronic records we sampled could be found in the 

locations identified in FHFA’s file plans. We found that FHFA records management training 

did not include all required content, and FHFA could neither demonstrate that required annual 

records management training was taken by all FHFA employees and contractor employees,

nor that required targeted records management training was delivered to all offboarded senior 

officials. Additionally, we found that a file plan for one FHFA division included records that 

did not link to a NARA-approved records schedule. 

Our audit also found another instance where FHFA was unable to account for contractor 

employees who onboarded during our review period. (In a 2019 audit, we found FHFA could 

not account for contractor employees who offboarded.) The related recommendation from that 

prior audit remains open as of the date of this report. This is a matter requiring continued and 

increased management attention. Because contractor employees have access to FHFA records, 

facilities, and systems, FHFA must ensure that such access has been authorized and the 

individuals trained in their responsibilities.

RECOMMENDATIONS ............................................................... 

We recommend that FHFA:

1. Ensure its permanent electronic records are located in and retrievable from FHFA’s

systems in accordance with division and office file plans.

2. Direct RIM to work with divisions and offices to review and update their respective 

file plans. That process should include ensuring the file plans include the location of 

all records, are complete, and link to NARA-approved records schedules. 
OIG • AUD-2020-008 • March 26, 2020 19

3. Include all NARA-required content topics in annual records management training 

provided to FHFA employees and contractor employees. 

4. Develop and implement procedures to ensure: 

a. FHFA employees and contractor employees complete required annual records 

management training; 

b. Contractor employees complete required records management training at time of 

onboarding; and 

c. FHFA senior officials (political appointees, senior agency officials, and senior 

executives) complete required targeted records management training at time of 

offboarding. 

FHFA COMMENTS AND OIG RESPONSE ..................................... 

We provided FHFA an opportunity to respond to a draft of this audit report. FHFA provided 

technical comments on the draft report and those comments were considered in finalizing this 

report. FHFA also provided a management response, which is included in Appendix B of this 

report. In its management response, FHFA agreed with the four recommendations and plans 

to take corrective action on or before March 15, 2021. 

As its corrective actions for recommendation 1, FHFA plans to research the feasibility 

of enhancing the search, navigation, and reporting capabilities of its eRIM tool;23 revise 

procedures to include Division and Office subject matter experts’ responsibilities when 

searching for or identifying records; issue guidance that once a record is approved, it should 

be declared and properly cataloged; and conduct compliance reviews of FHFA office file 

plans by randomly selecting sample records to review and determine compliance with the 

office’s file plan. To the extent that FHFA’s response to recommendation 1 ensures that 

the location of all existing permanent electronic records can be found based on the location 

identified in the record’s respective file plan, we consider FHFA’s planned corrective action 

responsive to our recommendation. 

For recommendations 2, 3, and 4, we consider FHFA’s planned corrective actions stated in its 

management response in Appendix B as responsive to our recommendations. 

23 eRIM is a tool FHFA developed to manage records throughout their lifecycle.
OIG • AUD-2020-008 • March 26, 2020 20

OBJECTIVE, SCOPE, AND METHODOLOGY ................................. 

The objective of the audit was to determine if FHFA achieved the records management goals 

included in the OMB and NARA joint directive OMB Memorandum M-12-18, Managing 

Government Records, and incorporated into OMB Memorandum M-19-21, Transition to 

Electronic Records, except for Goal 1.2 (by December 31, 2016, Federal agencies were to 

manage both permanent and temporary email records in an accessible electronic format).

To accomplish our objective, we: 

• Reviewed Presidential Memorandum—Managing Government Records, November 

28, 2011; M-12-18; M-19-21; as well as applicable NARA bulletins;

• Reviewed laws and regulations related to records management including: the Federal 

Records Act of 1950; 44 U.S.C. Chapter 31 – Records Management by Federal 

Agencies; 36 C.F.R. Chapter XII Subchapter B – Records Management; and OMB 

Circular A-130, Managing Information as a Strategic Resource; 

• Reviewed FHFA’s Records and Information Management Policy, along with RIM 

procedures and other RIM materials;

• Reviewed FHFA’s annual Senior Agency Official for Records Management reports 

submitted to NARA for 2013 through 2018; 

• Interviewed FHFA officials regarding records management and their implementation 

of six of the seven goals included in M-12-18; and

• Analyzed FHFA’s implementation of six of the seven goals included in M-12-18: 

o For Goal 1.1 (by December 31, 2019, Federal agencies will manage all 

permanent electronic records in an electronic format), we tested whether 28 

permanent electronic records could be retrieved based on the location of the 

record type in the applicable division/office file plan;

o Inquired with FHFA officials about how FHFA manages permanent electronic 

records from predecessor agencies (Office of Federal Housing Enterprise 

Oversight, the Federal Housing Finance Board, and the Government Sponsored 

Entity mission office at the Department of Housing and Urban Development). 

FHFA officials informed us that there are no permanent electronic records 

from predecessor agencies and that all electronic records from predecessor 

agencies have a disposition of temporary. 
OIG • AUD-2020-008 • March 26, 2020 21

o For Goal 2.1 (Agencies Must Designate a Senior Agency Official), we 

reviewed NARA’s website to determine whether FHFA had designated a 

SAO for records management. We analyzed FHFA’s organizational chart to 

determine whether the SAO is located within the organization so as to have 

sufficient authority to make adjustments to agency practices, personnel, and 

funding as may be necessary to ensure compliance and support the business 

needs of the department or agency. We also interviewed FHFA’s SAO about 

his views on his authority to carry out the responsibilities for ensuring that 

FHFA complied with records management statutes and regulations;

o For Goal 2.2 (SAO Shall Ensure that Permanent Records are Identified for 

Transfer and Reported to NARA), we reviewed FHFA’s tracking spreadsheet 

that contained a listing of permanent records originating from predecessor 

agencies to determine whether the records that are 30 years old, as of 

December 31, 2019, have been transferred or are scheduled to be transferred to 

NARA at a future date;

o For Goal 2.3 (Agency Records Officers Must Obtain NARA Certificate of 

Federal Records Management Training), we reviewed FHFA’s documentation 

and communication with NARA to determine whether FHFA’s records officer 

obtained the NARA Certificate of Federal Records Management Training by 

December 31, 2014; 

o For Goal 2.4 (Agencies Must Establish Records Management Training), we 

tested whether:

o FHFA included all of the training requirements (totaling 15 required 

topics) set forth in NARA Bulletin 2017-01, Agency Records 

Management Training Requirements; 

o All FHFA employees and contractor employees completed the 2019 

annual records management training; 

o Selected FHFA employees had an understanding of their records 

management responsibilities. Specifically, we interviewed eight 

employees from five FHFA divisions/offices with records management 

responsibilities. We used a standard questionnaire for these interviews;

o New hire employees and contractor employees completed the required 

training; and 
OIG • AUD-2020-008 • March 26, 2020 22

o Senior officials who onboarded and offboarded between January 1, 

2019, and November 30, 2019, were provided targeted records 

management training. 

o For Goal 2.5 (SAO Shall Ensure that Records are Scheduled), we determined 

whether FHFA’s CRS was approved by NARA and whether records that 

FHFA identified in its file plans for 2019 were linked to a records schedule 

(FHFA’s CRS or NARA’s GRS).

We conducted this performance audit between October 2019 and March 2020 in accordance 

with generally accepted government auditing standards. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on our audit 

objectives.
OIG • AUD-2020-008 • March 26, 2020 23

APPENDIX A: FHFA’S 28 PERMANENT ELECTRONIC 

RECORDS SELECTED FOR RETRIEVAL BY OIG ............................. 

Permanent Electronic Records Retrieved But Not in the Location as Identified in the Applicable File Plan24

1 Division of Enterprise Regulation (DER): 2018 Report of Examination for Fannie Mae

2 DER: 2018 Report of Examination for Freddie Mac

3 DER: Conclusion Letter, April 10, 2019

4 DER: Conclusion Letter, January 9, 2019

5 DER: Conclusion Letter, January 23, 2019

6 DER: Conclusion Letter, January 22, 2019

7 DER: Conclusion Letter, March 5, 2019

8 DER: Conclusion Letter, May 9, 2019

9 DER: Conclusion Letter, February 5, 2019

10 DER: Conclusion Letter, April 9, 2019

11 DER: Conclusion Letter, January 23, 2019

12 DER: Conclusion Letter, March 5, 2019

13 Division of Bank Regulation (DBR): 2018 ROE for the Federal Home Loan Bank of Topeka

14 DBR: 2019 ROE for Federal Home Loan Bank of New York

15 Office of Congressional Affairs and Communications - 2018 Annual Report to Congress

16 Office of Congressional Affairs and Communications – News Release: FHFA Announces Key Hires, 

November 20, 2019

17 Office of Budget and Financial Management: 2019 Performance and Accountability Report

18 Division of Housing Mission and Goals (DHMG): FHFA’s 2019 Annual Housing Report

19 Division of Conservatorship: STAR Information Technology System – Common Securitization 

Solutions Operating Agreement – Release 2 Go-Live Operational Launch, April 30, 2019

Permanent Electronic Records Not in the Location as Identified in the Applicable File Plan

for which OIG Performed No Further Search of FHFA’s Systems24

1 DBR: Public Use Data - Single-Family Mortgage-Level Owner-Occupied 1-Unit Properties (National 

File A) 2018 Data

2 DBR: Public Use Data: Single-Family Unit-Level Properties (1-4), includes Renter-Occupied 1-Unit 

Properties (National File B) 2018 Data

3 Office of the Director: Dr. Calabria’s Testimony Before the U.S. Senate Committee on Banking, 

Housing, and Urban Affairs “Housing Finance Reform: Next Steps,” September 10, 2019

4 Office of the Director: Schedules of Official Activities 

5 Office of Congressional Affairs and Communications - News Release: FHFA Updates Progress on 

Fannie Mae and Freddie Mac Credit Risk Transfer Programs, November 12, 2019

6 DHMG: Staff Analysis - 97% Loan-to-Value First-Time Home Buyer Loan Program, December 3, 2014

7 DHMG: Mortgage Loan Integrated System Database 

8 DHMG: National Mortgage Database: Aggregate Data: National Statistics for New Residential 

Mortgages in the United States, December 18, 2019

9 DHMG: National Mortgage Database: Aggregate Data: National Delinquency Rates in the United 

States, December 18, 2019 

24 Additional details on the identity of the selected records was provided to FHFA separately.
OIG • AUD-2020-008 • March 26, 2020 24

APPENDIX B: FHFA MANAGEMENT RESPONSE .......................... 
OIG • AUD-2020-008 • March 26, 2020 25
OIG • AUD-2020-008 • March 26, 2020 26
OIG • AUD-2020-008 • March 26, 2020 27

ADDITIONAL INFORMATION AND COPIES ................................. 

For additional copies of this report: 

• Call: 202-730-0880 

• Fax: 202-318-0239 

• Visit: www.fhfaoig.gov

To report potential fraud, waste, abuse, mismanagement, or any other kind of criminal or 

noncriminal misconduct relative to FHFA’s programs or operations:

• Call: 1-800-793-7724 

• Fax: 202-318-0358 

• Visit: www.fhfaoig.gov/ReportFraud

• Write:

FHFA Office of Inspector General

Attn: Office of Investigations – Hotline

400 Seventh Street SW 

Washington, DC 20219