PCACJIG 

Fann Credit Administration 

Office of Inspector General 

Farm Credit Administration 

Office of Inspector General 

Inspection Report 

Farm Credit Administration’s 

External Communication Process 

I-22-01 

August 2, 2022 
PCA0IG 

Farm Credit Administration 

Office of Inspector General August 2, 2022 

The Honorable Glen R. Smith, Board Chairman 

The Honorable Jeffery S. Hall, Board Member 

Farm Credit Administration 

1501 Farm Credit Drive 

McLean, Virginia 22102-5090 

Dear Chairman Smith and Board Member Hall: 

The Office of Inspector General completed an inspection of the Farm Credit Administration’s (FCA) 

external communication process. The objective of this inspection was to determine whether FCA has 

an effective and efficient external communication process. 

During the inspection, we found that FCA initiated and extended a social media presence over the 

last decade, developed policies and procedures on social media, and maintained a website. The 

Office of Congressional and Public Affairs had developed draft internal procedures identifying 

specific roles and responsibilities of the office and its personnel. We also found in testing of 

certain website requirements that FCA had complied with selected elements that we reviewed and 

hired an external contractor to aid with website compliance. 

However, we identified opportunities to improve the utilization and overall effectiveness of social media 

communications. The controls over social media and the FCA website need to be 

updated, implemented, and improved. Certain processes were not clearly defined or documented, 

and other processes were documented but not implemented. Applicable policies and procedures 

were also outdated. 

We made five recommendations to improve the external communication process. Management agreed 

or partially agreed with the recommendations and provided corrective actions that were responsive to 

our recommendations. Although Management partially agreed with recommendation 1, the 

corrective actions address the intent of the findings and recommendations. We find the 

provided actions responsive to the recommendations. 

We appreciate the courtesies and professionalism extended by FCA to our staff during the 

inspection. If you have any questions about this inspection, we would be pleased to meet with 

you at your convenience. 

Respectfully, 

Sonya K. Cerne 

Assistant Inspector General for Audits, Inspections, and Evaluations 

1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general 
EXECUTIVE SUMMARY 

FCA’s External Communication Process 

Report No. I-22-01 August 2, 2022 

Objective 

The objective of this inspection is 

to determine whether FCA has 

an effective and efficient external 

communication process. 

Recommendations 

The Office of Inspector General 

made five recommendations to 

the Office of Congressional and 

Public Affairs to enhance the 

external communication process. 

The recommendations relate to 

analyzing social media efforts and 

strategies, developing and 

documenting controls, and 

documenting and implementing 

policies and procedures. 

Agency Response 

Management agreed or partially 

agreed with, and provided 

corrective actions for, all 

recommendations. Although 

Management only partially agreed 

to recommendation 1, the actions 

are responsive to the intent of the 

recommendation and the 

findings. 

Why We Did This Inspection 

The Farm Credit Administration (FCA or Agency) communicates with its 

stakeholders in a variety of ways to increase awareness, support, and

understanding of the Agency’s financial regulator role. The external 

communication process is integral to the Agency and ensures 

consistency and accuracy in messaging. 

How We Did This Inspection 

We reviewed FCA’s processes for certain external communication, 

including the FCA website, social media accounts, and policies and 

procedures. We reviewed the content on FCA’s social media accounts. 

We sampled and tested approvals for social media postings. We also 

tested select provisions of website requirements. 

What We Found 

During the inspection, we found that FCA initiated and extended a 

social media presence over the last decade, developed policies and 

procedures on social media, and maintained a website. OCPA had 

developed draft internal procedures identifying specific roles and 

responsibilities of the office and its personnel. We also found in testing 

of certain website requirements that FCA had complied with selected

elements and hired an external contractor to aid with website 

compliance requirements. 

However, we found that FCA’s use of social media is quite limited, 

providing opportunities to improve the utilization and overall 

effectiveness of these communications. The controls over social media 

and the FCA website need to be updated, implemented, and improved. 

Certain processes were not clearly defined or documented. Other 

processes were documented but not implemented. Applicable policies 

and procedures were also outdated. 
TABLE OF CONTENTS 

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

Farm Credit Administration ....................................................................................................................................1 

Office of Congressional and Public Affairs........................................................................................................1 

External Communication Mechanisms ...............................................................................................................2 

Related Policies, Procedures, and Plans.............................................................................................................2 

Prior Office of Inspector General Reports .........................................................................................................3 

Objective, Scope, and Methodology ........................................................................................... 4 

Objective........................................................................................................................................................................4 

Scope...............................................................................................................................................................................4 

Methodology................................................................................................................................................................4 

Inspection Results ......................................................................................................................... 5 

Social Media Presence..............................................................................................................................................6 

Unverified Social Media Accounts........................................................................................................................7 

Social Media Disclaimers .........................................................................................................................................8 

Controls over External Communication .............................................................................................................8 

Approval Process for Social Media Posts ..........................................................................................................9 

Access to FCA Social Media Accounts ............................................................................................................. 10 

FCA.gov Website...................................................................................................................................................... 10 

Records Maintenance ............................................................................................................................................ 11 

Root Causes ............................................................................................................................................................... 11 

Social Media Strategy ............................................................................................................................................ 11 

Policies and Procedures ........................................................................................................................................ 12 

Impact.......................................................................................................................................................................... 12 

Recommendations .................................................................................................................................................. 13 

Management Comments ............................................................................................................ 15 

Acronyms and Abbreviations..................................................................................................... 17 
BACKGROUND 

Farm Credit Administration 

The Farm Credit Administration (FCA or Agency) is an independent federal agency responsible for 

regulating and supervising the Farm Credit System (System) and the Federal Agricultural 

Mortgage Corporation. The Agency is responsible for ensuring that all System institutions are safe, 

sound, and dependable sources of credit and related services for all creditworthy and eligible

persons in agriculture and rural America. In order to successfully achieve its mission, FCA has an 

external communication process to communicate messages, publications, reports, and other 

important information relating to the Agency. 

Office of Congressional and Public Affairs 

FCA’s Office of Congressional and Public Affairs (OCPA) serves as the Agency’s principal point of 

contact for media, System institutions, System borrowers, and the public. OCPA serves as FCA’s 

congressional liaison and also provides information to The mission of the Office of external audiences through news releases, fact sheets, Congressional and Public reports, videos, and other publications. Content on the FCA 

Affairs is “to direct all agency website and social media accounts is also managed by OCPA. congressional activities; to 

OCPA works with other Agency offices to plan and prepare manage the coordination and 

Agency communications. However, OCPA is responsible for production of all Agency 

approving all information produced for external audiences public information and 

before the product is disseminated.1 OCPA reviews Agencywide internal 

information products for editorial and design purposes and communication; and to build 

to ensure consistency and compliance with certain awareness, support, and 

requirements, such as the Plain Writing Act of 2010. These understanding of the 

products include new or revised publications and important role the Farm 

information posted on the FCA website and social media Credit Administration plays in 

accounts. ensuring the prosperity of 

agriculture and rural 

OCPA is divided into two components, congressional affairs America.” 

and public affairs. The office is led by the Director who 

oversees the Deputy Director and two congressional affairs 

staff members. The Deputy Director supervises staff serving in public affairs, program support, 

and administrative assistant roles. The office also utilizes contractors for services that include 

writing and editing, video recording and production, and website maintenance and compliance. 

1 OCPA does not approve Office of Inspector General products and publications. 

1 
External Communication Mechanisms 

FCA utilizes many mechanisms and mediums for external communication. The FCA website is 

intended to serve as the primary source of information for all external audiences. FCA’s website 

serves as a hub for information relating to the Agency, laws and regulations affecting the Agency 

and System oversight, and other news. External stakeholders can also sign-up to be notified via 

email about all publicly released documents. FCA also utilizes certain social media platforms to 

communicate with outside audiences. Currently, these platforms include: 

Twitter- a platform to 

communicate through 

quick, frequent 

messages, which may 

contain photos, videos, 

links, and text. A 

message posted to 

twitter is called a tweet. 

Facebook- a platform 

that allows 

organizations to 

connect with users by 

posting content that is 

visible to users that like 

or follow the 

organization’s page. 

YouTube- a platform to 

watch and share 

videos. Youtube 

channels are used to 

establish a public 

presence by uploading 

videos. 

LinkedIn- a platform 

for organizations to 

post professional 

information such as 

industry updates, job 

opportunities, and 

other information 

about their 

organization. 

Related Policies, Procedures, and Plans 

OCPA has several policies and procedures relating to the external communication process. The 

following Policies and Procedures Manual (PPM) sections are most applicable to this inspection: 

2 
PPM 201, Information Release PolicyThe policy's stated purpose is to 

provide for the uniform release and 

distribution of public information in 

a manner consistent with applicable 

laws, regulations, and Agency policy. 

PPM 202, FCA Publications and 

World Wide Web Homepage PolicyThe policy sets forth the manner of 

approval for all official FCA 

publications and information 

produced for electronic 

dissemination on FCA’s home page. 

PPM 205, Policy for Official Use of 

Social Media- The policy covers FCA’s 

creation, maintenance, and 

monitoring of all social media

applications, channels, content, and 

profiles with consideration of

security, privacy, and transparency. 

OCPA also has a draft internal procedures manual. The manual outlines: 

• work and organization of OCPA, 

• congressional affairs activities and procedures, 

• borrower complaints, 

• public affairs, 

• administration of the office, and 

• processes and templates for certain types of communications. 

In addition, OCPA activities are outlined in the OCPA Operating Plan. The Fiscal Years 2021-2022 

Operating Plan covers the responsibilities of the office by function. The plan also outlines OCPA’s 

mission, and how the office’s objectives and activities help achieve Agency goals. 

Prior Office of Inspector General Reports 

The Office of Inspector General (OIG) issued a management advisory report in September 2012, 

Survey of the Farm Credit Administration’s Use of Social Media (M-12-01). The objective of the 

review was to determine the extent that FCA and its employees used social media tools and to 

review FCA’s governance, risk management, awareness training, and monitoring of social media. 

The advisory report was completed before FCA adopted an active social media presence and 

included a survey of employees on their uses of social media tools. The report made six 

suggestions to the Agency pertaining to a social media presence, monitoring social media 

platforms, and annual security awareness training. 

3 
OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

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

external communication process. 

Scope 

The inspection was conducted at FCA from February 2022 through June 2022. The scope of the 

inspection was limited to certain external communication processes. We limited our testing to 

certain areas as noted below in the methodology section. 

Methodology 

We took the following steps to accomplish the objective: 

• Identified and reviewed applicable laws, regulations, guidance, and other background 

information applicable to the objective. 

• Identified and reviewed applicable internal FCA policies and procedures. 

• Reviewed prior FCA OIG and other external reviews related to the inspection objective. 

• Interviewed selected OCPA and Office of Information Technology (OIT) personnel 

responsible for external communication and FCA’s website oversight. 

Tests Performed 

 Determined FCA’s social media presence by reviewing FCA’s website and social media 

accounts. 

 Reviewed the verification processes, which ensure accounts are authentic, for Facebook, 

Twitter, LinkedIn and YouTube accounts. 

 Reviewed selected agencies’ social media presence to understand FCA’s content, reach, 

and practices in comparison to other federal financial regulatory agencies. We compared

follower/subscriber numbers and verification information, based on publicly available

information, to FCA accounts. 

 Requested and reviewed accesses to the social media accounts and website controls and 

determined if accesses were appropriate for staff roles and responsibilities. 

 Determined the approval process for social media postings by reviewing posting to FCA’s 

Facebook and Twitter accounts for the January 1, 2021 to December 31, 2021 timeframe. 

We judgmentally sampled 30 selected social media activities to review approvals from the 

Office of General Counsel (OGC) and OCPA. The sample was based on the date of the 

4 
approvals, type of posting, and the approval procedures. Because the sample was 

judgmental, it cannot be projected to the population. 

 Reviewed requirements set forth in U.S. Office of Management and Budget (OMB) 

Memorandum M-17-06, Policies for Federal Agency Public Websites and Digital Services. 

Selected certain requirements and tested whether the FCA website contained the required 

information. Selected requirements for testing were based on the objective and scope of 

the inspection and applicability to the FCA website. Because the sample was judgmental, 

it cannot be projected to the population. 

 Reviewed and analyzed the OCPA social media tracker for record retention practices. We 

selected all social media posts for 2021 that were maintained as official records. Because 

the sample was judgmental, it cannot be projected to the population. 

 Reviewed position descriptions and internal procedures to determine what roles and 

responsibilities were assigned to OCPA staff. 

Quality Standards for Inspection and Evaluation 

This inspection was performed in accordance with the Council of the Inspectors General on 

Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards require 

that we plan and perform the inspection to obtain sufficient and appropriate evidence that

provides a reasonable basis for our findings, conclusions, and recommendations. We assessed 

internal controls and compliance with laws and regulations to the extent necessary to satisfy the 

objective. Because our review was limited, it would not necessarily have disclosed all internal 

control deficiencies that may have existed at the time of our inspection. We assessed the 

information and data collected during the inspection and determined it was sufficiently reliable 

and valid for use in meeting the inspection objective. We assessed the risk of fraud related to our 

inspection objective while evaluating evidence and had no matters come to our attention 

indicating fraud or illegals acts were occurring; however, our review was limited to the inspection 

objective. Overall, we believe the evidence obtained is appropriate and sufficient to provide a 

reasonable basis for our findings and conclusions based on the inspection objective. 

INSPECTION RESULTS 

During the inspection, we found that FCA initiated and expanded its social media presence over 

the last decade, developed policies and procedures on social media, and maintained the Agency 

website. OCPA identified specific roles and responsibilities of the office and its personnel. We also 

found, in testing certain website requirements, that FCA had maintained required elements on its 

website and hired a contractor to aid with compliance requirements. 

However, we found FCA’s use of social media to be quite limited, and that the Agency conducted 

no analysis of the effectiveness of its social media communications. Controls over social media 

and the FCA website need to be updated, implemented, and improved, and certain processes are 

not clearly defined or documented. Other processes were documented but not implemented. 

5 
Social Media Presence 

FCA has a social media presence on Facebook, Twitter, LinkedIn, and YouTube. FCA’s PPM 205, 

Policy for Official Use of Social Media, states that social media is a group of online tools and 

services that encourage interaction and engagement among the individuals who use these tools. 

The PPM also explains FCA uses social media as a strategic communication tool to facilitate both 

internal and external communication and that the benefits include: 

• improving the Agency’s reach to diverse audiences; 

• furthering the delivery of consistent, timely, repetitive, and tailored/targeted messages; 

and 

• facilitating engagement and transparency. 

Social Media Use and Reach 

Before implementing social media, the Agency gathered information through an internal 

workgroup to study potentially using social media. In 2012, the FCA Social Media Workgroup2 

recommended that FCA adopt a limited social media program to serve two purposes: 

• First, to help the Agency communicate more effectively with and better educate its 

audiences. The Social Media Workgroup’s proposal explains that different demographic 

groups rely on different communication platforms, and by communicating on different 

platforms, FCA could cater to the preferences of our audience demographics. 

• Second, social media would help FCA get information out quickly in the event of a crisis. 

The proposal explains that responding quickly during times of crisis can prevent or 

minimize further crises. 

Initially, FCA utilized LinkedIn and YouTube for social media posts. It was not until 2018 that FCA 

expanded its use of social media by utilizing Twitter and Facebook accounts. The proposal 

presented to leadership to add these social media accounts stated key themes for the Agency’s 

social media posts could include economic information in the agricultural industry as well as the 

System’s status and leadership. The proposal also stated that the Agency could use social media 

posts to recruit job seekers and correct any misinformation about the Agency that might have

been provided by other sources. 

We found that FCA’s use of social media could be improved. We sampled FCA’s postings on 

Twitter and Facebook from January 1, 2021 to December 31, 2021.

3 For the year, FCA posted about 

80 different times on each platform. The majority of FCA posts we sampled were hiring 

announcements and notices of FCA board meetings. However, we noted other federal financial 

regulatory agencies use social media to communicate on various topics. Examples of content 

2 The Social Media Workgroup was led by the Director of OCPA and consisted of representatives from OCPA, 

what is now the Office of Agency Services, the Office of Examination and OGC. 3 In general, content is simultaneously posted to the Agency’s Facebook and Twitter accounts. YouTube and 

LinkedIn postings were not included in the sample. 

6 
shared by these agencies includes education on the Agency’s role and mission, information on 

employee programs and initiatives, cybersecurity, special emphasis programs, and consumer 

protection information. The number of social media followers/subscribers could be affected by 

the type and frequency of posted content. Differing missions and stakeholders could also affect 

the number of followers/subscribers. However, FCA may be able to use some of the content ideas 

from other accounts. 

The following table shows a comparison of FCA’s social media accounts and followers/subscribers 

as compared to other selected federal financial regulatory agencies for the same four social media 

platforms utilized by FCA: 

FCA’s Social Media Presence Compared to Other Select Federal

Financial Regulatory Agencies as of March 2022 

Name of Organization Facebook 

Followers 

Twitter 

Followers 

LinkedIn 

Followers 

YouTube 

Subscribers 

Farm Credit Administration 273 248 3,859 116 

Commodity Futures Trading 

Commission 29,000 60,800 6,857 2,180 

Federal Deposit Insurance 

Corporation 21,000 32,600 70,006 7,430 

Federal Housing Finance 

Agency 

2,400 26,000 17,317 831 

Federal Reserve Board 35,000 879,200 84,603 1,110 

National Credit Union 

Administration 10,000 10,400 26,333 3,160 

Office of the Comptroller of the 

Currency4 22,000 31,900 51,463 1,068 

Securities and Exchange 

Commission 32,000 430,200 87,665 7,830 

Unverified Social Media Accounts 

While FCA’s YouTube channel is verified, its Facebook and Twitter accounts are not considered 

verified. The verification badge (check mark) next to the Facebook and Twitter account name and 

YouTube channel lets users know that an account of public interest is authentic. Each social 

network utilized by FCA, except for LinkedIn,

5 has a process for applying for a verified account for 

organization accounts. For example, to receive the verification badge on a Twitter account, the 

4 The Office of the Comptroller of the Currency is an independent bureau within the United States 

Department of Treasury.

5 LinkedIn has a verification process for individual accounts only and not organization accounts. 

7 
account must be authentic, notable, and active. Specifically, for government Twitter accounts, 

there are two prerequisites. First, the account includes a relevant link to an official government 

web address on its profile. Second, the account must satisfy the criteria outlined for an “active 

account.” Although Twitter suspended its verification process in 2017, it reinitiated this process in 

2021. 

Spoofed Social Media Account 

We also found that while FCA had not increased its social media usage to include Instagram, there 

appeared to be a spoofed account on Instagram that was using the FCA logo and information. 

The account posted images and information attempting to represent the Agency and linked to a 

dating site. The Agency was unaware of the spoofed account during our review. 

The Agency’s Privacy Impact Assessment for social media addresses the risk that individuals may 

set up a third-party social media site and claim it to be an official FCA social media presence. To 

negate these false sites, the Privacy Impact Assessment states that all Agency social media sites 

have been appropriately branded. It also notes that this branding allows the public to know that 

this is an official FCA social media presence, and that they can trust the information. However, this 

example shows the shortfall of that approach being that someone can copy the Agency’s 

branding. This also emphasizes the importance of periodically monitoring social media accounts. 

Social Media Disclaimers 

FCA’s social media accounts do not contain disclaimers presented in Agency policy. Implementing 

procedures in PPM 205 state that, “All official profiles must include a disclaimer based on Office 

of Management and Budget policy and the negotiated Terms of Service. The disclaimer should 

read as follows: Comments and images posted by the public do not necessarily represent the 

views of FCA. If you are looking for official FCA information, please go to www.fca.gov.” However, 

FCA’s accounts do not have the stated language or other disclaimers. 

Controls over External Communication 

FCA had implemented certain controls over external communication. For example, officials stated 

that notifications are generated when FCA is mentioned on social media accounts, which aids in 

monitoring information relating to the Agency. In addition, the FCA website included required

content. FCA also redesigned the website in 2018 to modernize, strengthen, clarify, and enhance

the site for readers. 

However, we identified controls over certain external communication processes that needed to 

be updated, implemented, and improved. Controls help ensure the consistency and accuracy of 

FCA’s external communication by allowing only those with authority to post content on behalf of 

the Agency in an approved manner. 

8 
Approval Process for Social Media Posts 

The approval process for social media posts was not fully documented and was inconsistently 

applied. In general, the process for creating social media content includes creating and staging 

the content, providing the content to OGC for approval, receiving final clearance from OCPA, and 

posting the content to social media. OCPA procedures covered posting on Facebook and Twitter; 

however, procedures for LinkedIn and YouTube were not documented. In addition, OCPA policies 

and procedures did not address: 

• the approval process for “liking” posts from the FCA social media account, 

• 6 retweeting and responding to tweets or other social media posts, 

• when social media posts need office director approval or involvement, and 

• the individuals or positions that have the authority to post on social media. 

To determine whether OCPA received approvals from OGC and OCPA leadership for social media 

posts, we judgmentally sampled posts, retweets,

7 and responses8 to tweets9 from FCA’s Facebook 

and Twitter accounts. We found inconsistencies with the social media approval process. 

Specifically, in our sample, we found that documentation was not provided showing approvals 

were received before release for the following: 

• 2 out of 16 posts lacked evidence of OGC approval. 

• 10 out of 16 posts lacked evidence of OCPA approval. 

• 8 out of 8 retweets lacked evidence of OGC approval. 

• 7 out of 8 retweets lacked evidence of OCPA approval. 

• 6 out of 6 Twitter responses lacked evidence of OGC approval. 

Officials stated that posts that are part of the ordinary course of business are approved by the 

OCPA Deputy Director and other posts are approved by the OCPA Director. However, this process 

was not documented. In addition, officials stated that OCPA approval for certain postings and

retweets was provided orally or by instant messenger. However, we could not verify those 

approvals because OCPA did not retain the approval documentation. Officials stated that OGC 

approvals were missing because the assigned attorney was out of the office. In addition, OCPA 

officials stated that there was a verbal agreement with the previous OGC approving official that 

retweeting or responding to tweets did not require OGC approval. However, this process was not 

documented. 

6 A retweet is defined as a forwarding of a tweet. 

7 We classified a retweet as those instances where FCA reposted a tweet. 8 We classified a Twitter response as those instances where FCA responded in Twitter to a posting. 9 We judgmentally sampled social media postings from Facebook and Twitter made between January 1, 

2021 and December 31, 2021 and approvals of postings by OGC and OCPA. Because the sample was 

judgmental, it cannot be projected to the population. 

9 
Access to FCA Social Media Accounts 

OCPA needs to improve controls over access to login information for FCA official social media 

accounts. OCPA policies and procedures did not designate those individuals with access and 

authority to post on social media. There were two people in OCPA who maintained the social 

media accounts. Although not officially documented, OCPA officials stated that there were three 

other FCA employees with authority to post on certain social media accounts given their role in 

the Agency. In addition, PPM 205 states that passwords for an official account must be unique to 

that account, the creator of each page must maintain a password that is distinct from his or her 

agency password, and passwords must be changed on all social media channels every 180 days 

for security purposes. 

However, account information is not secured in accordance with PPM 205. The draft OCPA 

procedures manual includes the shared username for all social media accounts and states the 

location of a document with social media passwords on a shared drive. The password document 

is located on a shared drive where multiple people have access to the information. To test 

accesses, we requested and reviewed a listing of all employees with access to the shared drive 

where the login information is stored. The two OCPA personnel that maintain the social media 

accounts were on the listing, but there were 13 additional FCA employees that have access to the 

login information that do not have the authority to post on FCA social media accounts. 

Additionally, an OCPA official stated that the social media passwords are only changed when 

someone that previously had access leaves the Agency. Not officially documenting those 

individuals with access and authority to post on social media, storing password information where 

it is accessible to those without access privileges, and not changing the password information 

decreases the security of FCA social media accounts. 

FCA.gov Website 

OCPA procedures did not fully document processes for the maintenance and security of the 

Agency’s website. FCA’s PPM 202, FCA Publications and World Wide Web Homepage Policy, 

outlines that OCPA has final approval authority for content. However, the PPM is one page in its 

entirety, was issued in 1998, and does not have detailed procedures on website content approvals, 

maintenance, or security. Additionally, the draft OCPA procedures manual addresses the process 

for updating subscriber lists and changing content, but it does not outline website controls. 

Missing items include roles and responsibilities between the various FCA offices and the 

contractor that is used for website updates and government compliance requirements. 

Other than the need to update PPM 202, we found no exceptions in our testing of certain website 

requirements. OMB Memorandum M-17-06, Policies for Federal Agency Public Websites and 

Digital Services, states that Federal websites and digital services should always meet and maintain 

high standards of effectiveness and usability and provide quality information that is readily 

accessible to all. We performed testing on certain requirements from OMB M-17-06 for 

searchability, privacy, security, and required links to specific information. All tested elements were 

included on FCA’s website. We also tested accesses to determine who could modify the FCA 

website. Accesses were limited to appropriate personnel. 

10 
Records Maintenance 

We found that OCPA needs to improve the recordkeeping process for social media content. The 

Federal Records Act generally defines Federal records as any material that is recorded, made, or 

received in the course of Federal business, regardless of its form or characteristics and is worthy 

of preservation. FCA’s PPM 205 addresses records maintenance requirements for social media 

stating, “if social media applications are used to conduct Agency business, employees are 

responsible for capturing the ‘record’ content and maintaining it for the appropriate retention 

period in an official FCA record-keeping system.” OCPA manages social media posts in a 

document on an internal shared drive. However, the document did not always match what was 

posted and included working draft notes and posts that were not published on the FCA accounts,

which can cause confusion on what is considered the official record. We also noted the social 

media records did not include copies of posted videos. OCPA needs to work with Agency records 

management personnel to improve this retention process. 

Root Causes 

We identified several root causes for weaknesses in the Agency’s external communication policies 

and practices that, if addressed, will improve the effectiveness and efficiency of FCA’s external 

communication process. 

Social Media Strategy 

When FCA planned to extend its social media presence in 2018, a recommended strategy was 

outlined that discussed social media usage, objectives, potential audiences, risks, and evaluation 

measures. The recommended strategy noted OCPA would evaluate the success of social media 

platforms by measuring growth, reach, engagement, and sentiment.10 The strategy explains that 

OCPA will monitor these metrics through measurements such as: 

• number of followers/likes we have and how much it’s growing quarterly; 

• relevance and type of followers, subscribers and people who like/follow us; 

• number of web traffic referrals from social media accounts to our website content; 

• feedback from followers; and 

• number of retweets. 

OCPA has the ability to pull up social media statistics from its social media accounts. FCA’s website 

contractors provide OCPA with monthly and weekly reports on social media traffic. It was also 

noted in the social media proposal that after Twitter and Facebook accounts were created, OCPA 

and the Social Media Workgroup would publish at least once a week for a 6-month period on 

10 The strategy defines growth as being determined by the number of friends, followers or likes. Reach is 

the amount of people exposed to content, including content that is shared. Engagement includes the 

number of interactions, their quality, and the influence of those that are engaging. Sentiment is a qualitative 

analysis of whether interactions are positive, negative, or neutral. 

11 
these new platforms. After this period, a review process will be held. However, OCPA personnel

stated that this review did not take place. 

Four years have now passed since FCA began increasing its social media presence, but FCA has 

not fully analyzed the use of social media accounts to understand how to optimize utilization and 

extend the reach of the messaging. In addition to measuring the growth, reach, engagement, and 

sentiment through the metrics set forth above, the Agency could evaluate content to reach more 

followers, posting frequency, results from activities on FCA’s social media sites with the social 

media content and activity of other federal financial regulatory agencies, and new social media 

tools and platforms. 

Policies and Procedures 

FCA has not designed and implemented comprehensive external communication policies and 

procedures. For example, two policies that relate to external communication processes, PPM 202, 

FCA Publications and World Wide Web Homepage Policy, and PPM 201, Information Release Policy, 

were both issued in 1998. The policies lack specificity on the roles and responsibilities relating to 

external communication processes and the current control structure. OCPA policies and 

procedures also describe processes that are not being implemented. For example, PPM 205, Policy 

for Official Use of Social Media, describes roles and responsibilities for FCA’s Social Media Council 

(Council) to maintain and monitor FCA’s social media profiles. However, the Council has not met 

since the social media profiles were established. Controls delegated to the Council in PPM 205 

included the following: 

• Council staff who maintain and monitor FCA social media profiles must commit time and 

resources to establish a profile or channel, moderate comments from the public, maintain 

security standards, and ensure compliance with Section 508 of the Rehabilitation Act of

1973. 

• The Council will develop guidelines that address the process, best practices, and technical 

specification for social media. 

• Responsible Council members must establish controls over FCA social media sites to 

ensure federal records are being captured and contact the FCA Records Officer for 

assistance determining record status. 

Not documenting roles and responsibilities may have contributed to certain issues noted in our 

inspection. For example, documented monitoring processes may have revealed unverified 

accounts, spoofed accounts, shared and unchanged passwords, and missing disclaimers. In 

addition, the OCPA procedures manual is a draft from January 2021 that has not been finalized 

and lacks details on approval processes, involvement with other offices such as OGC and OIT, 

access controls, and website maintenance and support requirements. 

Impact 

External communication is important to ensure the Agency effectively provides information to 

outside audiences to achieve its mission. An effective external communication program and 

12 
strategy supports consistent, timely, and accurate information sharing. Because communication 

methods and channels are evolving quickly, it is important for the Agency to understand current 

tools and reach relevant stakeholders. The recommendations set forth below are aimed at 

improving the Agency’s use of social media tools, strengthening controls, and improving 

documentation. 

Recommendations 

To enhance the 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. 

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. 

FCA Response 

Management partially agreed with recommendation 1. Management agreed to use the social 

media accounts to strengthen our recruiting efforts, develop posts highlighting the mission and

history of the Farm Credit System and FCA, and ensure FCA social media accounts follow System 

institution social media accounts to promote supported posts. 

FCA Management agreed with recommendations 2-5. Management stated it would continue to 

pursue verification for the Twitter and Facebook accounts. Management also agreed to document

social media processes and website procedures and finalize the OCPA procedures manual. 

Management’s estimated completion date for corrective actions is October 2022. 

13 
OIG Response 

The OIG finds the actions responsive to the recommendations. Although the Agency only partially 

agreed to recommendation 1, the actions are responsive to the intent of the recommendation 

and the findings. The provided responses for recommendations 2-5 also address the findings. 

Management comments can be found in the subsequent section. Management waived an exit 

conference. 

14 
Farm Credit Administration 1501 Farm Credit Drive 

Md..ean, VA 22102-5090 

(703) HBJ-4000 

Ju,ly 27, 2022 

To: 

Fm m:: 

Subject: 

rC.l - ¥e rnly Laguard:a 

FCA Irl5,ped:01· Gen eral 

Mi e stolk!ke, Dit·.rl:otr 

Office, of Cong1-essi:on:all a nd P l!:llic Afr: ·,.·s 

OCPA's response to the OJG's raft 1·e,po1t on its irispection of the agency's 

erlem ,al commun ication p -oce ss 

This m.emoraridum 1-esporids fo t r.e Jl!il:y 7 drafl: trep!llt from the Office of the, Jnspectoc 

General on its i111 spectfon of the Fa,m Credit Admin istration's extern.a! commun·cation 

process. lrne objective of the irispection was: to, detetmine whether FCA r.as an effective an d 

e'ffk ien. exte111:al commun·cation process, 

As a iresult of i:t:s inspection, th e. OIG is~ed fiv.e rncommendatfons, Follo wing is OCPA's 

rresporise to, earn 1-ecommerida . n. 

Recommelldation 1 .: The Office of Iris-pectm- GMeral recommends tlie Olr1ee of 

congressional and Puf:JHc AlrairS analy21e tile use of sodal media aa:-ou-lll:S rn understand how 

to optimize eotttellt and ex.tend the ~ of the messagit19·. 

We pa t iialL'y ag1-ee with this ireoommemlati0111. OOPA ma tmag;emen intentiorialliy ~ oped 

atmd mainta·rn s a limited socia ll medj,a, program, Out• goa l is to focus: 0111 messagirn g that 

rrellates di ·edliy to the missi0111 and r.istoiry of the agency a nd th.e IFa m 0 redit System. 

We ag1-ee tl\iat this irn spe,ction tre,pOlt identified a reas \-.Jhetre ..-.·e can im prove 011tr sociial media, 

program. We appreciate the, OIG's care ful! inspectiorn a nd look forwa n l to, improving ou · 

program furtherr by more th.o.-01.1 gnliy docum enting o ut· processes and using social media 

pllatfoims fo dlisbn<bute, more COil e nt rrelated to, the • m issi:on a nd history of the, agency a nd 

t ile Fa1m Onedit System. 

Recommet1dation z ; -ine Office of It1:5peeto.r Gene.al recommends tlie Olfi..e of' 

Congressional and Pu!:J,ic AlrairS pu-rS-u-e verificatitm of' the Farm Credi Admini#ratit:m 

Tvritt,er .na FtJCebook. accounts. 

We ag,-ee with this 1-ecomme ndlation. We iiave, a l ·eacly begun purs uing velifica ti0111 of botr. 

01.1 tr T\,..ftte1" a ira cl Facebook acco irats. 

MANAGEMENT COMMENTS 

15 
Ju ly 27, 2022 

Pag;e 2 

Recommemiation 3 : Tne Office of Inspecro.r Genera'/ remmmends the Office cf 

Gc>ngressional and Public Affairs, in crxm:/1.natitm with applicabfe offfces, dcm.mrent social 

rnedia proce.sses ro include: 

• approval processes~ 

• mm:-riroring responsibifities, 

• raquired disclaimers, 

• password protection, ,and 

• l"eCCJrds ret.e.rttion. 

W,e ag,-ee witii this 1-ernmme irndation. 'We ,...,illl document OOJ • appn :i111a l pn1cesses an d ou1· 

monitoring 1-esponsibi'lities. We will a l!so, insert a ny necessa1y d isdlaime rs. We• have alraady 

sliorecl up mu pass1r,'01d seal ·ity a nd ,...,ifl doa.Jmen the -ste ps neoessal'Y fo maintain seal ·ity 

going fo111n<a ·d , Also, "''e will be ,.,.10,-king witlrn the agency's raoon:ls officia l to ensu -e that "''e 

ha ve a, process for effi cielliltlfi, 1-etain·ng pe1m a nen rrecoirds. 

Recommemiation 4: Tne Office of Inspecro.r Genera'I remmmends the Office cf 

(;ongressiona! and Pub lic Affairs, in crxm:/1.natitm with other appficabJe, offices~ document 

website pnxedure.s that: include roles and' n?Sponsibil'ities for website m aintenance and 

.se,;;urity. 

We ag,-ee witii this recomme ndation. We will oooroinate wi'th t ile Office• o Infol'l!Tia tion 

Tecllnology to ensu -e• tha t we are documenting 1r;,ebiSite procedures con-edl:y, We ,..,ill also 

cllarify \'!lho, is i-esponsibfe foir pahi:icula1· t asks. 

Recommenda tion 5: Tne Office of li,,specror Genera'l !"eCOfflrnends the Office cf 

(;ongressiona! and Public Affairs update and finalize ,'the Office of Ccmgr essionaJ and' Public: 

Affairs p nxedu,es manual. 

W,e ag,-ee witii this 1-ernmmendation. We will upda. e a nd fiirn a llze 0 111' pn x:edures ma nual. 

Tlia nk youi for tile oppotbmity to, i-espond to tllese-1-ecomme mlations. We l'ook fon,ra1°d to 

using you · feed'b:ad c to imprnve-the agency's socia l media prngiram. 

16 
ACRONYMS AND ABBREVIATIONS 

Agency Farm Credit Administration 

Council FCA’s Social Media Council 

FCA Farm Credit Administration 

OCPA Office of Congressional and Public Affairs 

OGC Office of General Counsel 

OIG Office of Inspector General 

OIT Office of Information Technology 

OMB U.S. Office of Management and Budget 

PPM Policies and Procedures Manual 

System Farm Credit System 

17 
Fann Credit Administration 

Office of Inspector General 

REPORT FRAUD, WASTE, ABUSE, & 

MISMANAGEMENT: 

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

(703) 883-4316 

Fax: (703) 883-4059 

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.