FARM REDIT DMINISTRATION

OFFICE OF INSPECTOR GENERAL

C A

SEMIANNUAL REPORT TO CONGRESS

APRIL 1, 2022 – SEPTEMBER 30, 2022

i 

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

A MESSAGE FROM THE INSPECTOR GENERAL

I am pleased to submit our Semiannual Report to Congress, summarizing the activities 

and accomplishments of the Farm Credit Administration (FCA or Agency) Office 

of Inspector General (OIG) for April 1, 2022, through September 30, 2022. 

Having concluded another six months as FCA’s Inspector General, I am delighted to 

say that our office has had another productive reporting period. We delivered

informative and valuable reports on FCA’s efforts to establish an enterprise risk 

management and internal control program as well as the Agency’s external

communication process, which together included a total of thirteen recommendations 

to improve the administration of these functions. Our office also oversaw a contracted audit of the 

Agency’s compliance with the Federal Information Security Modernization Act, conducted on an 

abbreviated timetable mandated by government-wide guidance. Simultaneously, this reporting period 

saw our office undergo two required peer reviews, on both our audit and inspection and evaluation 

programs. I am proud that both reviews resulted in our office receiving the highest ratings possible.

Outside of our audit, inspection, and evaluation work, we continued to exercise diligence in providing 

comprehensive oversight of FCA programs and operations. Among other things, we received and 

responded to hotline complaints, issued a report on our surveys of Farm Credit System institutions, and 

observed our obligations to keep the FCA Board and Congress fully and currently informed regarding 

problems and deficiencies in the administration of Agency programs and operations.

These six months also continued to see our office make an impact government-wide through 

participation in the various committees and working groups of the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE). On that score, I am particularly happy to report that Sonya Cerne, our 

Assistant Inspector General for Audits, Inspections, and Evaluations, was selected to receive the Sentner 

Award for Dedication and Courage at the 25th Annual CIGIE Awards Ceremony. This award—one of the 

Inspector General community’s highest honors—recognizes her uncommon selflessness and dedication 

to duty in leadership of the CIGIE Inspection and Evaluation Committee.

I would like to thank FCA personnel at all levels for another reporting period during which our work was 

received with courtesy and professionalism. I also express my appreciation to the Board for its April 2022 

message on cooperation with the OIG, which once again highlighted our office’s role and encouraged 

employees to promptly report fraud, waste, and abuse.

Finally, I take this opportunity to welcome Board Chairman Vincent G. Logan to FCA. Filling a long-vacant 

seat on the Board, Chairman Logan was confirmed by the Senate in late September, sworn in on October 

13, and designated Board Chairman on October 21. I very much look forward to working with Chairman 

Logan, as well as Board Members Jeffery S. Hall and Glen R. Smith, in furtherance of the Agency’s vital

mission.

Wendy R. Laguarda

Inspector General
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Semiannual Report to Congress 

April 1, 2022 – September 30, 2022 

Farm Credit Administration | Office of Inspector General 

A Message from the Inspector General ................................................................................................................................ i

Acronyms and Abbreviations .................................................................................................................................................. iii

Background ..................................................................................................................................................................................... 1

Strategic Plan ................................................................................................................................................................................. 3

Performance Measures ............................................................................................................................................................... 4

Audits, Inspections, and Evaluations ..................................................................................................................................... 7

Investigations .............................................................................................................................................................................. 13

Other Reports and Reviews ................................................................................................................................................... 14

Outreach, Collaboration, and Other Initiatives ............................................................................................................... 15

Appendix I: Peer Reviews ........................................................................................................................................................ 17

Appendix II: Reports Issued ................................................................................................................................................... 19

Appendix III: Reports with Questioned Costs ................................................................................................................. 20

Appendix IV: Reports With Recommendations That Funds Be Put to Better Use ............................................ 21

Appendix V: Open Recommendations .............................................................................................................................. 22

Index of Reporting Requirements ....................................................................................................................................... 23

TABLE OF CONTENTS
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

ACRONYMS AND ABBREVIATIONS

CIGIE Council of the Inspectors General on Integrity and Efficiency

ERM Enterprise Risk Management

Farm Credit Act Farm Credit Act of 1971, as amended

Farmer Mac Federal Agricultural Mortgage Corporation

FCA (or Agency) Farm Credit Administration

FISMA Federal Information Security Modernization Act of 2014

FY Fiscal Year

I&E Inspection and Evaluation

IG Inspector General

IG Act Inspector General Act of 1978, as amended

OCPA Office of Congressional and Public Affairs

OIG Office of Inspector General

OMB U.S. Office of Management and Budget

Pub. L. Public Law

System Farm Credit System

Williams Adley Williams Adley & Company-DC, LLP

U.S. United States

U.S.C. United States Code
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

BACKGROUND

The Farm Credit System

First established in 1916, the Farm Credit System (System) is a nationwide network of borrower-owned 

cooperative financial institutions and service organizations. A government-sponsored enterprise, the 

System is designed to better the income and well-being of farmers, ranchers, and rural America by 

providing a safe and reliable source of credit and related financial services.

As of July 1, 2022, the System consisted of three farm credit banks, one agricultural credit bank, one 

federal land credit association and 63 agricultural credit associations that primarily make loans to 

agriculture in all 50 states and Puerto Rico, as well as six service corporations that provide administrative, 

technology-related, and other support services to certain System entities and eligible borrowers. The 

System raises funds by selling securities in the national and international money markets through the 

Federal Farm Credit Banks Funding Corporation.

The System also includes the Federal Agricultural Mortgage Corporation (Farmer Mac), a stockholderowned, federally chartered instrumentality. Created in 1988, Farmer Mac provides a secondary market for 

agricultural real estate mortgage loans, rural housing loans, and rural utility cooperative loans. Farmer 

Mac is publicly traded and issues its own debt securities. 

The Farm Credit Administration

The Farm Credit Administration (FCA or Agency) is the independent federal 

agency responsible for ensuring that the System remains a dependable source 

of credit for agriculture and rural America. Authorized by the Farm Credit Act of 

1971, as amended1 (Farm Credit Act), FCA ensures the safety and soundness of 

System institutions by issuing policies and regulations and by regularly examining System institutions.

FCA has five offices and over 300 employees.

FCA is overseen by a three-person board, members of which are appointed by the President, with the 

advice and consent of the Senate. The Chair—who is designated by the President and serves in that role 

until the end of the Chair’s term—also serves as the Agency’s Chief Executive Officer. During the reporting 

period, the Board had two members, Board Chairman Glen R. Smith and Board Member Jeffery S. Hall.

On April 6, 2022, President Biden announced his intent to nominate Vincent G. Logan to serve on the 

Board. The Senate unanimously confirmed Mr. Logan on September 29, 2022, and he was sworn in on 

October 13, 2022. Subsequently, on October 21, 2022, the President designated Mr. Logan as Board 

Chairman.

The Office of Inspector General

Established in January 1989, the Office of Inspector General (OIG) is charged with the task of providing 

independent and objective oversight of FCA programs and operations. It carries out this responsibility as 

authorized by and in accordance with the Inspector General Act of 1978, as amended2 (IG Act), by 

1 12 U.S.C. § 2001 et seq.

2 5 U.S.C. app.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

conducting and supervising audits, inspections, evaluations, and investigations; promoting economy and 

efficiency; preventing and detecting fraud, waste, and abuse; and keeping the FCA Board and Congress 

fully and currently informed about problems and deficiencies related to FCA.

Located within FCA, the OIG operates independently—outside the direction of 

Agency leadership. While the Inspector General (IG) is appointed by and serves 

under the general supervision of the FCA Board, neither the Board nor any other 

Agency official may prevent or prohibit the IG from carrying out an oversight 

activity that the IG determines to be necessary or appropriate. The IG also exercises discretion in OIG 

employment and contracting decisions, further safeguarding the office’s independent status. This 

independence is necessary to ensure that OIG products meet the highest standards of objectivity and 

credibility.

The OIG is led by Wendy R. Laguarda, who has served as the IG since August 2017. Reporting to the IG 

are the Assistant Inspector General for Audits, Inspections, and Evaluations, the Investigator, and the 

Counsel to the Inspector General. The Assistant Inspector General supervises the audit staff and oversees 

the audit, inspection, and evaluation functions.

The Council of the Inspectors General on Integrity and Efficiency

The FCA IG also serves as a member of the Council of the Inspectors General on Integrity and Efficiency 

(CIGIE). Composed of the federal inspectors general and certain other federal officials, CIGIE 

was established to address cross-agency issues of integrity, economy, and effectiveness 

and to improve the professionalism and effectiveness of OIG personnel. OIG staff regularly 

participate on CIGIE committees and initiatives, as discussed in this report.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

STRATEGIC PLAN

In September 2019, the OIG adopted a five-year strategic plan for 

fiscal years (FYs) 2020 to 2024. Revised in 2021, the plan details the 

vision, mission, values, goals, and objectives of the OIG in carrying 

out its responsibilities under the IG Act.

The OIG’s vision, mission, values, and goals are outlined below. 

Vision

Harvesting Change

Mission

To provide independent oversight to promote economy, efficiency, 

and effectiveness, and prevent and detect fraud, waste, and abuse in 

Farm Credit Administration programs and operations

Values

Objectivity, Integrity, Relevance, and Respect

Goals

1) Promote Economy and Efficiency

2) Prevent and Detect Fraud, Waste, and Abuse

3) Strengthen Internal and External Relationships 
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

PERFORMANCE MEASURES

The OIG’s strategic plan for FYs 2020 to 2024, revised in September 2021, sets forth several measures 

against which the OIG assesses its performance. Each of these performance measures is associated with 

one of the OIG’s strategic objectives, which in turn serve the office’s strategic goals. The following 

describes some of the OIG’s actions that were relevant to those performance measures during FY 2022, 

which encompassed this six-month reporting period as well as the immediately preceding period.

Strategic Objective 1.1 Execute value-added audits, inspections, and evaluations

Annually develop an oversight agenda based on Agency mission, risk, activities, and management.

In October 2021, the OIG published an audit, inspection, and evaluation plan for FYs 2022 and 2023. 

Complete products in an average time of six months. 

The OIG completed seven audit, inspection, and evaluation projects in an average time of 156.1 days, 

under six months (182.5 days). Excluding matters performed under contract by external firms, the OIG 

completed four projects in an average time of 148 days.

At least annually, complete a quality assurance review to ensure compliance with professional 

standards and office policies and procedures.

As discussed later in this report, the OIG completed an internal quality assurance review of its audit, 

inspection, and evaluation functions on July 28, 2022. 

Strategic Objective 1.2 Produce impactful products

Make recommendations, as necessary, to management and monthly track recommendation status 

until closure.

The OIG made 27 recommendations during FY 2022. The OIG tracked the status of those 

recommendations on an ongoing basis through its follow-up database and reported open 

recommendations to the FCA Board on a monthly basis. The OIG also maintained a list of open 

recommendations on Oversight.gov.

Strategic Objective 1.3 Ensure we have a diverse, professional, and highly skilled workforce

Comply with mandatory training requirements and maintain professional certifications.

All OIG staff remained on track to meet training requirements and maintain certifications as required by 

OIG policy and relevant professional standards.

Promote diversity, equity, inclusion, and accessibility. 

During FY 2022, the OIG endeavored to improve office awareness and consciousness of diversity, equity, 

inclusion, and accessibility issues through training, participation in FCA special emphasis programs, and 

involvement in the CIGIE Diversity, Equity, and Inclusion Work Group. 
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

Strategic Objective 2.1 Address potential matters of wrongdoing and misconduct with 

proficiency, independence, and due professional care

Initially evaluate all FCA OIG hotline calls, emails, and other submissions within two business days 

of receipt.

Of 32 complaints received during FY 2022, the OIG initially evaluated and acknowledged (or, where 

acknowledgement was not possible, acted upon) 27 complaints (84%) within two business days of receipt.

Monthly track the status of allegations and investigations to ensure timely actions.

The OIG tracked the status of all allegations received on an ongoing basis, and monthly reported their 

status to the FCA Board.

Perform or undergo annual reviews to ensure investigative activities are conducted in accordance 

with quality standards and internal policies and procedures.

The OIG did not conduct any investigations in FY 2022 and, as a consequence, did not conduct an 

investigative quality assurance review. 

Strategic Objective 2.2 Provide an independent mechanism to report fraud, waste, and abuse

Maintain a hotline from a source independent of the Agency.

Throughout the fiscal year, the OIG maintained a hotline email account procured through a commercial 

provider.

Promote awareness of hotline avenues.

The OIG promoted awareness of the various ways to submit complaints on the OIG’s website, on the back 

cover of OIG reports, through posters displayed in Agency common areas, and during presentations to 

FCA employees. 

Strategic Objective 2.3 Educate employees and contractors on fraud and whistleblower rights and 

protections

At least twice annually, educate employees on fraud, waste, abuse, mismanagement, and 

whistleblower protections.

The OIG educated FCA employees on these subjects as part of presentations to new employees, during 

meetings with new Agency supervisors, and in the OIG’s quarterly intra-agency newsletter. 

Strategic Objective 3.1 Listen to and understand the needs, challenges, and interests of our 

stakeholders 

Monthly track reviews of relevant existing or proposed legislation and regulations. 

In FY 2022, the OIG generally reported on comments submitted on proposed legislation as part of 

monthly status reports but did not document all items reviewed. As discussed later in this report, pursuant 

to an internal control review, the OIG adopted a new policy in September 2022 to provide for more 

comprehensive tracking of OIG reviews of legislation, regulations, and policies.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

Quarterly conduct a confidential survey of Farm Credit System institutions on the effectiveness of 

the Agency’s examination program.

The OIG surveyed System institutions on a quarterly basis throughout FY 2022. The OIG published survey 

reports on July 18, 2022, covering institutions examined during the first two quarters of FY 2022, and on

January 21, 2022, covering institutions examined during the second, third, and fourth quarters of FY 2021.

Annually conduct at least four outreach initiatives with employees.

During FY 2022, the OIG conducted outreach to FCA employees through presentations to new employees

at an Office of Examination conference and the issuance of its intra-agency newsletter, the dIG. 

Strategic Objective 3.2 Report to and fully inform the FCA Board and Congress

Issue the OIG Semiannual Report to Congress within 30 days of the end of each reporting period.

During FY 2022, the OIG transmitted its Semiannual Reports to Congress to the FCA Board on April 28, 

2022 and October 26, 2021, respectively.

At least annually, brief Congressional oversight committees on OIG activities.

The OIG provided virtual briefings to majority and minority staff of the House and Senate agricultural 

oversight committees twice during FY 2022. 

Post all audit, inspection, and evaluation reports within three business days of issuance to the FCA 

Board.

All final audit, inspection, and evaluation reports issued during FY 2022 were posted to the OIG’s website 

and to Oversight.gov within three business days of issuance to the FCA Board.

At least quarterly, brief FCA Board members on OIG activities.

The IG provided briefings to each FCA Board member on a quarterly basis in FY 2022. 

Strategic Objective 3.3 Participate in and engage with the IG Community

Monthly participate in CIGIE committees, work groups, or initiatives.

As discussed in greater detail later in this report, OIG personnel participated extensively in CIGIE 

committees and work groups throughout FY 2022.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

AUDITS, INSPECTIONS, AND EVALUATIONS

The OIG regularly performs audits, inspections, and evaluations of FCA programs and operations. In so 

doing, OIG personnel seek to provide timely, credible, and relevant information to Agency leadership, 

Congress, other stakeholders, and the general public. FCA OIG audits are performed in accordance with

the Government Auditing Standards issued by the U.S. 

Government Accountability Office, while inspections and 

evaluations adhere to the CIGIE Quality Standards for 

Inspection and Evaluation. 

n planning its audits, inspections, and evaluations, the OIG 

mploys a risk-based approach that accounts for prior 

versight work, the control environment, input from the FCA 

ard and senior management, statutory requirements, and 

ources. For more information, and to learn about future 

 work, please see the audit, inspection, and evaluation 

I

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o

Bo

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OIG

plan for FYs 2023 and 2024. 

Reports issued may be found on the OIG website within three business days of issuance to the FCA Board. 

To receive a notification when a new report is published, please subscribe to the OIG mailing list. Reports 

are also posted on Oversight.gov, a consolidated repository for the oversight work of federal inspectors 

general. Oversight.gov allows users to sort, search, 

and filter the site’s database to find reports of 

interest. Users can receive notifications when new 

reports are added to Oversight.gov by following CIGIE’s Twitter account, @OversightGov. 

Summaries of Reports Issued 

The OIG issued three reports and made fifteen recommendations for corrective action during the 

reporting period. The reports are summarized below.

Farm Credit Administration’s External Communication Process

I-22-01

External communications serve an integral role in carrying out FCA’s statutory mission. News releases, 

fact sheets, reports, videos, and other publications—whether distributed through the FCA website, social 

media platforms, or other means—serve to promote awareness, support, and understanding of the 

Agency’s role and inform stakeholders. Within FCA, the Office of Congressional and Public Affairs (OCPA) 

serves as the principal point of contact for System institutions, System borrowers, Congress, and the 

public. OCPA works with other Agency offices to prepare communications, approving all information 

produced for external audiences prior to its dissemination.

The objective of this inspection was to determine whether FCA has an effective and efficient external 

communication process. In pursuit of this objective, the OIG reviewed FCA’s processes for handling certain 

communications, including information distributed through the FCA website and on its social media 

accounts. The OIG compared the Agency’s social media presence with those of other federal financial 

regulatory agencies, examined the Agency’s social media procedures, and analyzed how the Agency 
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

retained records related to social media. The OIG also, among other things, tested whether the Agency’s 

website included certain types of information required by U.S. Office of Management and Budget (OMB) 

guidance.

The OIG found that while the Agency had created and expanded its social media presence in the past 

decade, opportunities for improvement existed. In reviewing a sample of social media posts from FCA 

and other federal financial regulatory agencies, the OIG found that FCA’s use of social media was limited. 

Whereas the majority of FCA posts concerned hiring announcements or notices of Board meetings, other 

agencies disseminated information on various topics, including their role and mission, employee 

programs and initiatives, cybersecurity, and consumer protection. The OIG noted that FCA may be able 

to use some of the content ideas offered by these other agencies on its own social media accounts and 

stated that the type and frequency of such content could affect subscriber and follower numbers.

The inspection determined that two of the Agency’s social media accounts were not considered verified, 

which would let users of the platform know that an account is authentic. The OIG also discovered a 

spoofed account on a social media platform not used by the Agency. Further, all Agency social media 

accounts omitted a disclaimer required by FCA policy, which states that comments and images posted by 

the public do not necessarily represent the Agency’s views.

While FCA had developed and implemented certain controls over its external communications, the OIG 

found others in need of updating, implementation, and improvement. For example, the Agency’s process 

for approving social media posts was not documented for some platforms. The OIG also found that OCPA 

lacked documentation regarding which employees were authorized to post on FCA social media accounts, 

that account login information was not secured in accordance with Agency policy, and that social media 

posts were not always captured in official Agency recordkeeping systems. With respect to the FCA 

website, the OIG noted that OCPA had not fully documented processes for its maintenance and security, 

but found no exceptions upon testing for certain governmentwide requirements for federal agency 

websites. 

The OIG discerned several root causes for the issues noted, including a lack of analysis regarding FCA’s

use of social media, which could help the Agency understand how to optimize utilization and extend the 

reach of its messaging. The OIG also identified the absence of comprehensive external communications 

policies and procedures.

The inspection report was issued on August 2, 2022. The OIG made five recommendations for corrective 

action. FCA agreed with, or partially agreed with, all recommendations. With respect to the one 

recommendation with which management partially agreed, the OIG determined that the Agency’s 

planned corrective action was responsive to the recommendation.

The Farm Credit Administration’s Compliance with the 

Federal Information Security Modernization Act for Fiscal Year 2022

A-22-02

Information technology facilitates and impacts all aspects of FCA operations. As such, securing Agency 

systems against cybersecurity threats and efficiently addressing requirements are vital to the fulfillment 

of FCA’s mission. Under the Federal Information Security Modernization Act of 20143 (FISMA), the OIG is 

3 44 U.S.C. § 3555(b)(1).
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

required to annually evaluate the FCA’s information security program and practices to determine their 

effectiveness. The OIG contracted with the independent public accounting firm of Williams Adley & 

Company-DC LLP (Williams Adley) to perform this review for FY 2022. The OIG monitored the work of 

Williams Adley for compliance with the Government Auditing Standards. 

In accordance with guidance developed by OMB, the U.S. Department of Homeland Security, and CIGIE, 

Williams Adley assessed FCA’s performance with respect to 20 core metrics across nine domains: risk 

management, supply chain risk management, configuration management, identity and access 

management, data protection and privacy, security training, information security continuous monitoring, 

incident response, and contingency planning. For each domain, FCA’s effectiveness was ranked according 

to a maturity model ranging from “ad-hoc” (level 1) to “optimized” (level 5). According to the FISMA 

metrics, a “managed and measurable” (level 4) information security program is considered to be 

operating at an effective level of security.

The focus on 20 core metrics marks a departure from prior years’ FISMA reviews, the most recent of which 

required assessment of 66 metrics. Along with this change, OMB guidance shifted the due date for 

FY 2022 FISMA reports from October to July to better align the release of OIG assessments with 

development of the President’s budget.

Based on its auditors’ review of the 20 core metrics, Williams Adley concluded that FCA had implemented 

an effective security program for FY 2022. The Agency continued to improve its information security 

program and made progress in implementing the majority of recommendations made as part of previous 

FISMA evaluations. Williams Adley determined that the Agency was “managed and measurable” (level 4) 

for six domains. The information security continuous monitoring domain was “consistently implemented” 

(level 3), while Williams Adley determined the contingency planning and supply chain risk management 

domains to be “defined” (level 2).

The audit report was issued on July 25, 2022. Williams Adley made two recommendations, related to 

information security continuous monitoring and contingency planning, respectively. FCA agreed with 

both recommendations.

The OIG’s monitoring disclosed no instances where Williams Adley did not comply, in all material respects, 

with the Government Auditing Standards. 

Farm Credit Administration’s Enterprise Risk Management and Internal Control Program

A-22-01

In July 2016, OMB issued guidance requiring agencies to implement an Enterprise Risk Management 

(ERM) capability coordinated with agency strategic planning and internal control processes. While there 

are many ways to implement ERM, it generally comprises an approach for understanding the impacts of 

risks as an interrelated portfolio, rather than addressing those risks within silos. Another important factor 

for accountability, internal control refers to a process effected by an entity’s oversight body, management, 

and other personnel that provides reasonable assurance that the objectives of the entity are achieved. 

While each office within FCA has a role to play, the Office of the Chief Financial Officer (OCFO) is 

responsible for coordinating the Agency’s ERM and internal control efforts and ensuring compliance with 

associated requirements.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

The objective of this audit was to determine whether FCA had established an adequate ERM and internal 

control program. Among other things, the OIG reviewed Agency risk profiles and management control 

plans and analyzed a sample of the Agency’s internal control reviews.

While FCA had developed an ERM process, the OIG noted that improvements were needed with respect 

to risk monitoring, updating the Agency’s risk appetite, addressing risk, and providing communication 

and training on risk management. The OIG identified, as root causes for these issues, a lack of structured, 

formalized risk management processes and that the Agency’s ERM policy did not fully document specific 

procedures.

With regard to internal controls, the OIG found that the Agency had not fully documented or 

implemented its new risk and control self-assessment process. The OIG also noted inconsistences in the 

ratings assigned to risks identified by FCA, improvements regarding service organization reviews, and 

that the Agency lacked a process to monitor implementation of recommendations made as part of 

internal control reviews. The OIG determined several root causes for these issues, including a prolonged 

and inefficient implementation strategy for the Agency’s risk and control self-assessment process and a 

decentralized approach to tracking responses to internal control reviews

The audit report was issued on June 9, 2022. The OIG made eight recommendations to improve the 

Agency’s ERM and internal control program. FCA agreed with all recommendations.

Recommendations Made During the Reporting Period

Table 1 shows all recommendations for corrective action made during the reporting period.

Table 1 

Report Recommendation

Farm Credit 

Administration’s 

External Communication 

Process

1 The Office of Inspector General recommends the Office of 

Congressional and Public Affairs analyze the use of social media 

accounts to understand how to optimize content and extend the reach 

of the messaging.

2 The Office of Inspector General recommends the Office of 

Congressional and Public Affairs pursue verification of the Farm Credit 

Administration Twitter and Facebook accounts.

3 The Office of Inspector General recommends the Office of 

Congressional and Public Affairs, in coordination with applicable 

offices, document social media processes to include:

• approval processes,

• monitoring responsibilities,

• required disclaimers,

• password protection, and

• records retention. 
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Semiannual Report to Congress

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Farm Credit Administration | Office of Inspector General

Report Recommendation

Farm Credit 

Administration’s 

External Communication 

Process (continued)

4 The Office of Inspector General recommends the Office of 

Congressional and Public Affairs, in coordination with other applicable 

offices, document website procedures that include roles and 

responsibilities for website maintenance and security.

5 The Office of Inspector General recommends the Office of 

Congressional and Public Affairs update and finalize the Office of 

Congressional and Public Affairs procedures manual.

The Farm Credit 

Administration’s 

Compliance with the 

Federal Information 

Security Modernization 

Act for Fiscal Year 2022

1 Not publicly released.

2 Not publicly released.

Farm Credit 

Administration’s 

Enterprise Risk 

Management and 

Internal Control 

Program

1 The Office of Inspector General recommends the Office of the Chief 

Financial Officer develop and document structured processes for:

• Cross-organizational reviews of risks;

• Monitoring risk information throughout the year;

• Approving the risk profile;

• Updating the risk appetite;

• Evaluating strategies to address risk; and

• Providing communication and training to personnel with risk 

management responsibilities.

2 The Office of Inspector General recommends the Office of the Chief 

Financial Officer implement the current internal control review process 

across Farm Credit Administration offices.

3 The Office of Inspector General recommends the Office of the Chief 

Financial Officer update Policies and Procedures Manual 1007 and 

annual guidance to reflect the current internal control review process.

4 The Office of Inspector General recommends the Office of the Chief 

Financial Officer develop and document timelines for updating the 

Agency’s Management Control Plan.

5 The Office of Inspector General recommends the Office of the Chief 

Financial Officer develop and document a process to review service 

organization control reports.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

Report Recommendation

Farm Credit 

Administration’s 

Enterprise Risk 

Management and 

Internal Control 

Program (continued)

6 The Office of Inspector General recommends the Office of the Chief 

Financial Officer determine the needs of the Agency related to internal 

control reviewers.

7 The Office of Inspector General recommends the Office of the Chief 

Financial Officer train internal control reviewers on requirements and 

responsibilities.

8 The Office of Inspector General recommends the Office of the Chief 

Financial Officer develop and document a process to monitor gaps and 

recommendations identified in internal control reviews.

In Progress

Below are the audits, inspections, and evaluations in progress at the end of the reporting period.

Audit of the Farm Credit Administration’s Financial Statements

Fiscal Year 2022 

The Accountability of Tax Dollars Act of 2002 requires that FCA annually submit audited financial 

statements to Congress and OMB. Those financial statements must be audited by the IG or an 

independent external auditor, as determined by the IG. The OIG has contracted with the independent 

public accounting firm of Harper, Rains, Knight & Company, P.A., to perform this audit for FY 2022. The 

OIG is monitoring the work of the firm.

Audit of the Farm Credit Administration’s Examiner Staffing

Under the Farm Credit Act, FCA is required to examine each System institution no less than once every 

18 months. As such, recruitment and retention within the Office of Examination is vital to ensuring the 

System remains a dependable source of credit and related services for all creditworthy and eligible 

persons in agriculture and rural America. Rotating examiners is another important element of the 

Agency’s oversight, helping to ensure that examinations are fair, impartial, and independent. The 

objective of this audit is to evaluate FCA’s examination staffing processes. The review will cover the 

recruiting, scheduling, and retaining of examiners.
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Semiannual Report to Congress

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Farm Credit Administration | Office of Inspector General

INVESTIGATIONS

The OIG has broad discretion to carry out investigations related to FCA programs and operations that the 

IG determines to be necessary or appropriate. The range of matters falling within the OIG’s investigative 

purview is expansive, encompassing potential violations of law, rules, or regulations; mismanagement; 

abuses of authority; and more. Investigative activities may be initiated upon allegations or referrals 

received from a variety of sources, including, but not limited to, FCA employees or contractors, 

congressional committees, other agencies, System institutions, or members of the public. The OIG may 

also investigate potential fraud, waste, abuse, and mismanagement identified through OIG audits, 

inspections, and evaluations. 

In exercising its investigative authorities, the OIG works to develop products that are timely, clear, and 

credible, and to guard the identities of those who provide information to the OIG. All investigations are 

carried out in accordance with the CIGIE Quality Standards for Investigations. 

Table 2 summarizes major investigative activity during the reporting period.

Table 2 

Metric

Investigative reports issued4

Persons referred to the U.S. Department of Justice for criminal prosecution

Persons referred to state and local prosecuting authorities for criminal prosecution

Indictments and criminal informations that resulted from any prior referral to 

prosecuting authorities

Number

0

0

0

0

Complaint Activity

FCA employees and others may confidentially report potential fraud, waste, abuse, or mismanagement 

to the OIG in-person or via telephone, email, or mail. Table 3 shows the disposition of complaints received 

during the reporting period or carried over from a previous reporting period.

Table 3 

Action Taken Number

Investigation opened 0

Closed after review with no further specific investigative action 7

Referred to FCA program manager 2

Referred to other federal, state, or local agency or authority 0

Under review at the end of the reporting period 1

Total 10

Summaries of Investigations

The OIG did not conclude any investigations during the reporting period. Closing memoranda for 

investigations are available on the OIG’s online reports page. 

4 This metric does not include memoranda memorializing the closure or referral of complaints.
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Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

OTHER REPORTS AND REVIEWS

The OIG also conducts reviews that do not fit the description of an audit, inspection, evaluation, or 

investigation. These projects are typically undertaken in accordance with a statutory requirement, for 

quality assurance purposes, or to otherwise provide comprehensive oversight of FCA programs and 

operations. Below are summaries of such reviews that were completed during the reporting period.

2022 Internal Quality Assurance Review

The OIG annually conducts an internal quality assurance review of its audit, inspection, and evaluation 

functions to determine whether OIG procedures were established, implemented, and operating 

effectively. The review determined that internal policies and procedures were effective and followed for 

audits, inspections, and evaluations completed in FY 2022. Completed on July 28, 2022, the review noted 

no systemic issues or weaknesses and therefore made no recommendations.

Survey of Farm Credit System Institutions

Regarding the Agency’s Examination Function

Each quarter, the OIG surveys recently examined System institutions on the quality and consistency of 

FCA’s examination function. Survey questions seek the institution’s views on several matters, ranging from 

the appropriateness of the examination’s scope and the examiners’ conduct to the helpfulness of any 

recommendations or required actions. The survey employs a numerical rating system and allows for 

institutions to provide narrative responses as well as to call the OIG with any concerns. The OIG collects, 

aggregates, and anonymizes survey responses for distribution semiannually to the FCA Board and Chief 

Examiner.

The OIG issued a survey report on July 18, 2022, detailing responses from System institutions examined 

during the first two quarters of FY 2022. Prior survey reports are available on the OIG’s online reports 

page.

Internal Control Review of the Office of Inspector General 

Legislation and Regulations Review Function

In accordance with FCA policy, the OIG conducted an internal control review of the OIG’s legislation and 

regulations review function. This review focused on identifying associated risks and testing internal 

controls implemented to manage those risks. The review found that the OIG implemented various internal 

controls for the legislation and regulations review function but that improvements could be made in the 

documentation of policies and procedures, tracking of legislative reviews, and reporting in the semiannual 

reports to Congress. Completed July 14, 2022, the review made four recommendations to help effect 

these improvements.
15

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

OUTREACH, COLLABORATION, AND OTHER 

INITIATIVES

FCA Employees

The cooperation of FCA employees is essential to all aspects of OIG oversight. Accordingly, the OIG has 

several ongoing initiatives geared toward educating FCA employees on the OIG’s mission and authorities. 

These include a quarterly intra-agency newsletter, the dIG, which spotlights the office’s functions and 

provides recent examples of OIG oversight products government-wide. The OIG also participates in 

orientation training for new FCA employees and distributes posters to promote awareness of the OIG 

hotline. 

Congress

In the interest of fulfilling its responsibility to keep Congress fully and currently informed about problems 

and deficiencies relating to FCA programs and operations, the OIG endeavors to respond expeditiously 

to all congressional requests and to periodically brief oversight committees on recent OIG activity. In June

and July, the IG provided briefings on OIG activities to majority and minority staff from the Senate 

Committee on Agriculture, Nutrition, and Forestry and the House Committee on Agriculture.

Inspector General Community

The OIG is active in the IG community, with staff lending their efforts and expertise to the work of various

CIGIE committees, working groups, and initiatives.

Throughout the reporting period, IG Laguarda served as Chair of the CIGIE Inspection and Evaluation 

(I&E) Committee. One of CIGIE’s standing committees, the I&E Committee maintains professional 

standards for inspections and evaluations, heads the development of protocols for reviewing crossagency management issues, and oversees the I&E peer review process. Under the purview of this 

committee, the OIG’s Assistant Inspector General for Audits, Inspections, and Evaluations leads the I&E 

Roundtable. Of particular note, in June, the I&E Committee, Roundtable, and OIG personnel organized 

and presented at a virtual CIGIE town hall on the past, present, and future of inspections and evaluations. 

The event, which featured panel discussions on the I&E Roundtable and implementation of the CIGIE 

Quality Standards for Inspection and Evaluation as well as presentations on collaboration and the peer 

review process, drew nearly 500 participants from across the IG community.

The IG also served on the CIGIE Budget and Legislation Committees and as a member of the CIGIE IG 

candidate panel. The Legislation Committee fosters relationships with Congress, represents the IG 

community’s interests on legislative initiatives, and keeps OIGs apprised of pertinent legislative 

developments. The Budget Committee provides leadership in the development of CIGIE’s annual 

appropriation requests and coordinates with OMB and relevant Congressional committees on funding 

CIGIE activities. The IG candidate panel reviews potential IG candidates and makes recommendations to 

the appropriate appointing authority—the President or agency head. Finally, as Chair of the I&E 

Committee, IG Laguarda also sat on the CIGIE Executive Council, which assists in governance of CIGIE.
16

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

In addition to their involvement in the above-listed committees, OIG staff participated in a variety of CIGIE

committees and working groups, including the Audit Committee, the Diversity, Equity, Inclusion, and 

Accessibility Work Group, the Small and Unique IG working group, the Council of Counsels to the 

Inspectors General, the Assistant Inspectors General for Investigations Subcommittee, and the 

Whistleblower Protection Coordinators working group.

Reviews of Proposed Legislation, Regulations, and Policies

The OIG reviews proposed and existing legislation, regulations, and policies that affect Agency programs 

and operations or the mission and functions of the OIG. When appropriate, the OIG makes 

recommendations regarding the impact of such legislation, regulations, and policies on economy or 

efficiency, the prevention and detection of fraud, waste, and abuse, or the integrity and independence of 

the OIG. This reporting period saw the OIG review a variety of developments related to FCA or IG 

authorities. The OIG provided comments through CIGIE on the CIGIE Charter and proposed legislation 

concerning IG reporting requirements and other IG authorities.

Internal Operations and OIG Liaisons

The OIG is in continuous pursuit of ways to improve its own operations. During the reporting period, 

pursuant to a recommendation made as part of an internal control review, the OIG implemented a new 

internal directive addressing procedures for reviewing and commenting on proposed and existing 

legislation, regulations, and policies. The OIG, with FCA’s Office of Information Technology, also 

developed a new dedicated collaboration site to help document the OIG’s investigative activities. Finally, 

in order to help the OIG better assess risks facing the Agency, understand management challenges, and 

further improve cooperation between the OIG and management, the IG designated personnel to liaison 

with leadership of FCA’s component offices.
17

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

APPENDIX I: PEER REVIEWS

To ensure adherence to relevant professional standards, each OIG is subject to periodic external peer 

reviews. Information on peer reviews conducted by and of the FCA OIG is provided below.

Reports of external peer reviews of FCA OIG operations may be found on the OIG website. Reports of 

peer reviews conducted by the FCA OIG may be located on the websites of the reviewed OIGs.

Audit

The U.S. Government Accountability Office Government Auditing Standards require any organization 

conducting audits in accordance with those standards to undergo an external peer review at least once 

every three years. These peer reviews conclude in a rating of pass, pass with deficiencies, or fail. A rating 

of pass signifies that the audit organization’s system of quality control has been suitably designed and 

complied with to provide the organization with reasonable assurance of performing and reporting in 

conformity with applicable professional standards and legal and regulatory requirements in all material 

respects.

On June 9, 2022, the Federal Trade Commission OIG issued a final report of its peer review of the FCA 

OIG audit organization. The FCA OIG received the highest rating available, pass, with no letter of comment 

and no recommendations for corrective action.

The FCA OIG did not conduct any audit peer reviews during the reporting period.

Inspection and Evaluation

The CIGIE Quality Standards for Inspection and Evaluation require members of CIGIE that conduct 

inspections or evaluations under those standards to undergo an external peer review every three years. 

Inspection and evaluation peer review reports do not include an overall rating (such as pass or fail) but 

state whether the reviewed OIG’s policies and procedures were generally consistent with CIGIE standards 

and whether the OIG’s work generally complied with those standards.

On July 8, 2022, the Securities and Exchange Commission OIG issued a final report of its peer review of 

the FCA OIG inspection and evaluation organization. The FCA OIG received the highest rating available, 

with the report finding that FCA OIG’s policies and procedures generally were consistent with the 

standards addressed and that the reports reviewed generally complied with standards and FCA OIG’s 

policies and procedures. The report included no letter of comment and made no recommendations for 

corrective action.

The FCA OIG did not conduct any inspection and evaluation peer reviews during the reporting period.
18

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

Investigation

CIGIE’s Qualitative Assessment Review Guidelines for Investigative Operations of Federal Offices of Inspector 

General establish an independent external evaluation process for investigative operations. The objective 

of an investigative peer review is to determine whether internal control systems are in place and operating 

effectively to provide reasonable assurance that an OIG’s investigative operations comply with CIGIE’s 

Quality Standards for Investigations. Reviewed OIGs are assessed a rating of compliant or non-compliant. 

While the guidelines do not mandate that OIGs without statutory law enforcement authority—like the 

FCA OIG—undergo investigative peer reviews, they encourage voluntary participation.

The FCA OIG did not undergo an investigative peer review during the reporting period. The OIG’s 

investigative function is scheduled to be peer reviewed in summer 2023. The most recent peer review of 

the FCA OIG’s investigative program was performed by the Securities and Exchange Commission OIG for 

the one-year period ending September 30, 2007.

The FCA OIG did not conduct any investigative peer reviews during the reporting period.

Outstanding Recommendations

There are no outstanding recommendations from any peer review conducted by another OIG that have 

not been fully implemented.

There are no recommendations from any peer review conducted by the FCA OIG that remain outstanding 

or that have not been fully implemented. 
19

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

APPENDIX II: REPORTS ISSUED

Table 4 lists all audit, inspection, and evaluation reports issued during the reporting period. For each 

report, Table 4 lists the dollar value of questioned costs (including the dollar value of unsupported costs) 

and the dollar value of recommendations that funds be put to better use. 

Table 4

Report Title

Dollar Value of

Questioned Costs

Dollar Value of

Recommendations that 

Funds be Put to Better

Use Total Unsupported

Farm Credit Administration’s 

External Communication Process

$0 $0 $0

The Farm Credit Administration’s 

Compliance with the Federal

Information Security 

Modernization Act for Fiscal Year

2022

$0 $0 $0

Farm Credit Administration’s 

Enterprise Risk Management and

Internal Control Program

$0 $0 $0

Total $0 $0 $0
20

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

APPENDIX III: REPORTS WITH QUESTIONED COSTS

Table 5 shows the number of audit, inspection, and evaluation reports issued with questioned costs, and 

the total dollar value of questioned costs associated with those reports.

Table 5

Requirement # Questioned

Costs

Unsupported

Costs

(A) Reports for which no management decision had

been made by the commencement of the reporting

period

0 $0 $0

(B) Reports issued during the reporting period 0 $0 $0

Subtotal (A+B) 0 $0 $0

(C) Reports for which a management decision was made

during the reporting period, including— 

0 $0 $0

(i) the dollar value of disallowed costs $0 $0

(ii) the dollar value of costs not disallowed $0 $0

(D) Reports for which no management decision has 

been made by the end of the reporting period

0 $0 $0
21

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

APPENDIX IV: REPORTS WITH RECOMMENDATIONS 

THAT FUNDS BE PUT TO BETTER USE

Table 6 shows the number of audit, inspection, and evaluation reports issued with recommendations that 

funds be put to better use.

Requirement # Unsupported

Costs

(A) Reports for which no management decision had been made by the 

commencement of the reporting period

0 $0

(B) Reports issued during the reporting period 0 $0

Subtotal (A+B) 0 $0

(C) Reports for which a management decision was made during the 

reporting period, including— 

0 $0

(i) the dollar value of recommendations that were agreed to by 

management

$0

(ii) the dollar value of recommendations that were not agreed to by 

management

$0

(D) Reports for which no management decision has been made by the

end of the reporting period

0 $0

Table 6
22

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

APPENDIX V: OPEN RECOMMENDATIONS

Table 7 includes summary information regarding audit, inspection, and evaluation reports issued before 

April 1, 2022, for which there were outstanding unimplemented recommendations as of September 30, 

2022, including the aggregate potential cost savings of those recommendations. There were no reports 

issued before the commencement of the reporting period for which no management decision had been 

made by the end of the reporting period or for which no comment was returned within 60 days.

Table 7 

Report

Outstanding 

Unimplemented 

Recommendations

Aggregate Potential 

Cost Savings

The Farm Credit Administration’s Compliance 

with the Federal Information Security 

Modernization Act for Fiscal Year 2020

(October 30, 2020)

1 $0

The Office of Secondary Market Oversight’s 

Examination Policies and Procedures

(September 24, 2021)

1 $0

Total: 2 $0

Table 8 identifies recommendations made during previous reporting periods for which corrective action 

had not been completed as of September 30, 2022. An up-to-date list of open OIG recommendations 

may be found at Oversight.gov/recommendations. 

Table 8 

Report Recommendation

The Farm Credit 

Administration’s Compliance 

with the Federal Information 

Security Modernization Act for 

Fiscal Year 2020

6 Not publicly released.

The Office of Secondary Market 

Oversight’s Examination 

Policies and Procedures

2 The Office of Inspector General recommends the Office of 

Secondary Market Oversight document examination policies 

and procedures unique to the examination of the Federal 

Agricultural Mortgage Corporation.
23

Semiannual Report to Congress

April 1, 2022 – September 30, 2022

Farm Credit Administration | Office of Inspector General

INDEX OF REPORTING REQUIREMENTS

The following is an index to IG Act reporting requirements.

Section

4(a)(2)

5(a)(1)

5(a)(2)

5(a)(3)

5(a)(4)

5(a)(5)

5(a)(6)

5(a)(7)

5(a)(8)

5(a)(9)

5(a)(10)

5(a)(11)

5(a)(12)

5(a)(13)

5(a)(14)-(15)

5(a)(16)

5(a)(17)

5(a)(18)

5(a)(19)

5(a)(20)

5(a)(21)

5(a)(22)(A)

5(a)(22)(B)

Description

Review of legislation and regulations

Significant problems, abuses, and deficiencies

Recommendations for corrective action

Recommendations described in previous semiannual reports for which 

corrective action has not been completed

Matters referred to prosecutive authorities

Reports of information or assistance unreasonably refused or not

provided

Audit, inspection, and evaluation reports issued

Summaries of significant reports

Management decisions with respect to questioned costs

Management decisions on recommendations that funds be put to better 

use

Reports issued before the reporting period for which no management

decision has been made, for which no comment was returned, and for 

which there are outstanding unimplemented recommendations

Significant revised management decisions

Significant management decisions with which the IG disagrees

Information described under section 804(b) of the Federal Financial

Management Improvement Act of 1996

Peer reviews conducted by another OIG

Peer reviews conducted by the FCA OIG

Statistical tables for investigations and referrals

Metrics for developing investigative statistics

Investigations involving a senior government employee where

allegations of misconduct were substantiated

Instances of whistleblower retaliation

Attempts to interfere with OIG independence

Closed audits, inspections, and evaluations not disclosed to the public

Closed investigations involving a senior government employee not

disclosed to the public

Page

16

7-10

10-12

22

13

None

19

7-10

20

21

22

None

None

None

17-18

17-18

13

13

None

None

None

None

None

There were no contract audit reports issued during the reporting period that would be reportable under 

section 845 of the National Defense Authorization Act of 2008.5

5 Pub. L. 110-181 (Jan. 28, 2008).

REPORT FRAUD, WASTE, ABUSE, &

MISMANAGEMENT

Fraud, waste, abuse, and mismanagement in government concerns everyone: 

Office of Inspector General staff, Farm Credit Administration employees, 

Congress, and the general public. We actively solicit allegations of any fraud, 

inefficient and wasteful practices, abuse of authority, and mismanagement 

related to FCA programs and operations. You can report allegations to us in 

several ways:

Phone: (800) 437-7322 (Toll-Free)

(703) 883-4316

Email: fca-ig-hotline@rcn.com

Mail: 1501 Farm Credit Drive

McLean, VA 22102-5090

To learn more about reporting wrongdoing to the OIG, please visit our 

website at https://www.fca.gov/about/inspector-general.