FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

Semiannual Report to Congress

April 1, 2018 through September 30, 2018

FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

Message from the Inspector General

I am pleased to submit this Semiannual Report to Congress, which addresses the activities 

and accomplishments of the Office of Inspector General (OIG) in the Farm Credit 

Administration (FCA or Agency) for the period from April 1, 2018 through September 30, 

2018.

This year marked the 40th anniversary of the Inspector General Act and the creation of the 

original 12 Offices of Inspector General. The FCA OIG was established in 1989. Since that 

time, we have been part of a community that has grown to include 73 statutory Inspectors 

General who collectively oversee the operations of nearly every aspect of the federal 

government. Every six months, we provide Congress with a report detailing our independent 

oversight of FCA during the reporting period. In the years to come, we look forward to 

continuing our efforts to provide independent and effective oversight of the FCA and 

working with the Council of Inspectors General on Integrity and Efficiency (CIGIE) on 

important issues that cut across our government.

During this reporting period, the audit, inspection, and evaluation activities of our office 

focused on Agency physical security in two FCA field offices and at headquarters, and an 

evaluation study that benchmarked our information technology spending and use of 

contractors against the other federal financial regulators. Our investigator completed two 

preliminary investigations and one extensive formal investigation.

Our office continued to use the shared legal and investigative services of the Treasury 

Inspector General for Tax Administration (TIGTA). This arrangement is working out well, as 

the exceptional TIGTA staff has been very responsive to our requests for advice and support. 

Given that the costs of this arrangement have been minimal and the benefits substantial, we 

have renewed the agreement with TIGTA for another year.

Our office conscientiously carries out its reporting duties to the FCA Board and Congress. 

We held two quarterly briefings with each of the three members of the FCA Board and are 

scheduling meetings with our oversight committees in both the Senate and the House this 

fall. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

Message from the Inspector General

We continued our outreach efforts by publishing two issues of the dIG, our quarterly internal 

newsletter, and giving presentations about our office and its mission to new FCA employees 

and to the entire staff of the Office of Examination, FCA’s largest office. Though we are a 

staff of only five, we actively participate in CIGIE committees and workgroups, including the 

Inspections and Evaluations peer review workgroup and the committee to commemorate 

the 40th anniversary of the Inspector General Act of 1978. Two of our senior auditors also 

developed and taught a course on interviewing techniques for auditors and inspectors for

CIGIE’s training institute.

With a full complement of FCA Board members, we look forward to continued cooperation 

with the Board and Agency staff as we strive to improve Agency operations and programs. 

Wendy R. Laguarda

Inspector General
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

Abbreviations 

Agency Farm Credit Administration

CIGIE Council of the Inspectors General on Integrity and Efficiency

EXIM U.S. Export-Import Bank

Farmer Mac Federal Agricultural Mortgage Corporation 

FCA Farm Credit Administration

FISMA Federal Information Security Modernization Act of 2014

FLRA Federal Labor Relations Authority

FY Fiscal Year

HRK Harper, Rains, Knight & Company, P.A.

IAA Inter-Agency Agreement

IG Inspector General

IG Act Inspector General Act of 1978, as amended

IT Information Technology

OCPA Office of Congressional and Public Affairs

OE Office of Examination

OGC Office of General Counsel

OIG Office of Inspector General

OIT Office of Information Technology

OMB Office of Management and Budget

Pub. L. Public Law

ROI Report of Investigation

System Farm Credit System

TIGTA Treasury Inspector General for Tax Administration

U.S. United States
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

Table of Contents 

MISSION, VISION, VALUES, GOALS.......................................................................................................................... 1

BACKGROUND ................................................................................................................................................................. 2

STRATEGIC GOALS.......................................................................................................................................................... 6

PERFORMANCE MEASURES..................................................................................................................................... 10

AUDITS, INSPECTIONS, AND EVALUATIONS..................................................................................................... 12

Reports Issued .......................................................................................................................................................... 12

Table 1: Audit, Inspection, and Evaluation Reports Issued ................................................................. 12

Reports In Progress.................................................................................................................................................16 

Agreed-upon Actions............................................................................................................................................. 20

Table 2: Audit, Inspection, and Evaluation Agreed-Upon Actions ................................................... 20

Open Agreed-upon Actions ................................................................................................................................ 21

Table 3: Open Audit, Inspection, and Evaluation Agreed-Upon Actions....................................... 21

OTHER REPORTS .......................................................................................................................................................... 22

Survey of Farm Credit System Institutions..................................................................................................... 22

Management Advisory on the Farm Credit Administration Compensation Policy ........................ 23

Internal Quality Assurance Review.................................................................................................................... 24

INVESTIGATIONS.......................................................................................................................................................... 25

Table 4: Investigative Activity ......................................................................................................................... 27

LEGISLATIVE AND REGULATORY REVIEWS ........................................................................................................ 28

REPORTING AND OUTREACH ................................................................................................................................. 30

APPENDIX A: FCA Organizational Chart.............................................................................................................. 31

APPENDIX B: Peer Reviews ....................................................................................................................................... 32

APPENDIX C: Management Decisions.................................................................................................................. 34

APPENDIX D: Index of Reporting Requirements.............................................................................................. 35
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

1 

Mission, Vision, Values, Goals

Our Mission

The OIG’s independent eyes, ears, and voice serve to protect, inform, 

and advance Agency programs and operations.

Our Vision

Harvesting Change

Our Values

Relevant, Respectful, Trustworthy, and Objective

Our Goals

1. Detect and Deter Fraud, Waste, and Abuse 

2. Investigate and Protect Against Wrongdoing

3. Promote Quality and Value

4. Advance FCA’s Future 

GOAL 1

Perform risk-based 

audits, inspections, 

and evaluations

Reinforce the OIG as a 

safe zone for 

reporting fraud, 

waste, and abuse

Listen to and 

understand the needs, 

challenges, and 

interests of our 

stakeholders

GOAL 2

Guard confidentiality

Produce timely, clear, 

focused, and factual 

reports of 

investigation

Provide outreach on 

how to prevent fraud, 

waste, and abuse 

GOAL 3

Create benchmarks 

for improved Agency 

decision making

Ensure the OIG and 

FCA are models for 

good government

Produce OIG products 

that are timely, 

relevant, reasonable, 

and helpful

GOAL 4

Recruit, retain, and 

empower a diverse 

workforce

Promote leadership, 

vision, and expertise

Leverage technology

Source: FCA OIG’s Strategic Plan
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

2 

Background 

Farm Credit Administration

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

United States government responsible for the regulation and examination of Farm Credit 

System (System) institutions chartered under the Farm Credit Act of 1971, as amended. 

As a non-appropriated agency, FCA funds its expenses primarily by assessing System

institutions. FCA’s fiscal year (FY) 2018 budget limitation set by Congress was $70,600,000. 

As of the end of this reporting period, FCA had 307 full-time equivalent employees, 

about half of whom are examiners located in the Agency’s five field offices as shown 

below. 

Headquarters McLean, VA

Bloomington, MN

Sacramento, CA Denver, CO

Dallas, TX
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

3 

Background 

Farm Credit System

The System is a government-sponsored enterprise comprised of the following entities:

• 3 Farm Credit Banks, 1 Agricultural Credit Bank, and 69 Associations that primarily 

make loans to agriculture in all 50 states and Puerto Rico. The System raises funds 

by selling securities in the national and international money markets through its 

special purpose entity, the Federal Farm Credit Banks Funding Corporation. These 

securities are not guaranteed by the U.S. government. 

• The Federal Agricultural Mortgage Corporation (Farmer Mac), is a stockholderowned, federally chartered instrumentality of the United States. 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. 

• Five active service corporations that provide services to System to entities and 

eligible borrowers.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

4 

Background 

Office of Inspector General

The mission of the Office of Inspector General (OIG) is as follows:

The OIG’s independent eyes, ears, and voice serve to protect, 

inform, and advance Agency programs and operations.

The Inspector General Act of 1978, as amended (IG Act), established the FCA OIG in 1989. 

The Inspector General (IG) is appointed by the FCA Board without regard to political 

affiliation and solely based on integrity and demonstrated ability in accounting, 

auditing, financial analysis, management analysis, investigations, law, or public 

administration.

While the OIG is under the general supervision of the FCA Board, it operates with 

independent hiring, contracting, and budget authority. The IG reports both to the FCA Board 

and to Congress. 

The three major components of the OIG include audits, inspections, and evaluations of 

programs and operations, investigations, and outreach. 

Office of 

Inspector 

General

Audits, 

Inspections, and 

Evaluations

Investigations Outreach 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

5 

Background 

Office of Inspector General

OIG Staff With only five staff members (four full time and one part time), the 

OIG at FCA may be small in numbers, but our impact on FCA and 

the IG community is strong. Our three senior auditors have spent 

their careers in the IG community, and bring their knowledge, skills, 

and experience from other IG shops in the federal government to 

their current positions at FCA. Our newly trained investigator brings 

her legal background and knowledge of human resources to her 

position and has already had several opportunities to use her 

investigative skills. And the IG, with her legal and ethics background, 

has tackled her new duties this past year with enthusiasm and 

purpose. 

Our staff is continually improving its skills and knowledge by 

fulfilling continuing education requirements and participating in 

various committees, workgroups, cross-training opportunities, and 

other initiatives of the IG community. We are all deeply conscious 

of our oversight roles and the responsibility that comes with such 

authority. Hence, we strive always to be a model of good 

government and to ensure that our office follows best practices. 

Shared

Service 

Agreement 

with TIGTA

In November 2017, our office executed an Inter-Agency 

Agreement (IAA) with the Treasury Inspector General for Tax 

Administration (TIGTA) to obtain legal and investigative services, 

as necessary. The shared service arrangement with TIGTA 

provides us with vital support at minimal cost. The lawyers and 

investigators at TIGTA have been exceptionally responsive to, 

and helpful with, all our requests. Consequently, we renewed the 

IAA with TIGTA for fiscal year (FY) 2019 and are most grateful for 

their support.

The following organizational chart shows the OIG as of September 30, 2018:

Inspector General

Wendy Laguarda, JD

Senior Auditor

Tammy Rapp, CISA, CPA

Senior Auditor

Sonya Cerne, CFE

Senior Auditor

Tori Kaufman, CPA

Investigator

Ava Bell, JD
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

6 

Strategic Goals

To accomplish our mission, the OIG identified four strategic goals in our Strategic Plan. 

The following summarizes our strategic goals and related outcomes during this reporting 

period. 

Goal 1: Detect & Deter Fraud, Waste

& Abuse

Detecting and deterring fraud, waste, abuse, and mismanagement is critical to the OIG’s 

mission. We employ a multi-faceted approach in support of this goal: 

• Performs risk-based audits, inspections, and evaluations

• Reinforces the OIG as a safe zone for reporting fraud, waste, and abuse

• Listens to and understands the needs, challenges, and interests of our 

stakeholders

During this reporting period, we issued three inspection and evaluation reports, with 

four reviews in progress. The in-progress reviews include an evaluation of FCA’s 

compliance with the Federal Information Security Modernization Act of 2014 (FISMA), 

FCA’s financial audit, an Office of Examination (OE) benchmarking study, and a physical 

security inspection of headquarters. We also completed our internal quality assurance 

review and an external peer review report. 

The OIG hotline is available 24/7 to confidentially receive tips and complaints about 

fraud, waste, or abuse relating to FCA programs and operations. The OIG has telephone

and fax numbers, as well as an independent hotline email account available to the 

public. Only OIG staff have access to these avenues that allow individuals to report 

allegations to the OIG directly and confidentially. 

Communication with Agency stakeholders is another key aspect of the OIG’s oversight. 

During our reviews, we continually meet with Agency officials to keep them informed 

of our progress, results, and areas for improvement. The IG meets quarterly, or as 

needed, with FCA Board Members to discuss work products, priorities, and concerns. 

The IG and OIG staff also frequently interact with Agency staff and managers to obtain 

an understanding of their needs and challenges and to explain our oversight interests.

An OIG goal is to work diligently with Agency management to obtain agreement on 

planned actions addressing any recommendations resulting from an audit, inspection, 

or evaluation. Management identifies planned actions they will take to address any 

recommendations before we issue a final report. Once the OIG is satisfied with 

management’s planned actions, we convert our “recommendation” to an “agreed-upon 

action” before issuing our final report. In some instances, corrective action is completed 

prior to issuing a final report. We are pleased to recognize completed actions in the 

final report. During this reporting period, Agency management agreed with all our 

recommendations and developed corrective action plans.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

7 

Strategic Goals

Goal 2: Investigate & Protect Against WrongdoingThe OIG conducts timely, relevant, and high-quality investigations. Our investigative 

reports fairly and accurately report our findings and may offer actions for Agency 

consideration to correct and deter future misconduct, fraud, waste, or abuse. 

The OIG employs the following actions in support of this goal:

• Guards confidentiality

• Produces timely, clear, focused, and factual reports of investigation

• Provides outreach on how to prevent fraud, waste, and abuse

Our investigative procedures and internal controls are designed, to the extent possible, 

to guard the confidentiality of all complainants and persons involved in the 

investigative process. As provided by the IG Act, the OIG will not disclose the identity 

of a complainant without the consent of the complainant, unless the IG determines 

that such disclosure is unavoidable during an investigation or unless the complainant 

waives anonymity. To ensure all relevant aspects of the investigation are accurately 

and objectively addressed in our reports, our investigations manual describes, in part: 

the process for developing an investigation plan and obtaining IG approval; legal 

requirements during an investigation; communications and case management; 

reporting procedures; and referrals to FCA. The OIG follows the Council of Inspectors 

General on Integrity and Efficiency (CIGIE) Quality Standards for Investigations as 

guidance for all its investigative activity.

OIG evaluates all complaints, examining jurisdictional issues, the nature of the 

allegation, and other factors in determining whether to open an investigation. The OIG 

also assesses availability of records and other factors to determine whether the 

complaint includes allegations of criminal, civil, or administrative violations that 

necessitate a formal investigation. We also receive complaints from borrowers or 

potential borrowers in the System regarding their lending rights or alleged 

wrongdoing in a System institution. We refer these complaints to the FCA Office of 

Congressional and Public Affairs (OCPA), as required by Agency policy, and follow up, 

as appropriate. During this reporting period, the OIG reviewed 20 complaints and 

conducted one formal investigation and two preliminary investigations. 

The OIG participates in FCA’s new employee training to discuss our investigative 

program, and we distribute posters identifying hotline contact information, as well as 

Office of Special Counsel notices on whistleblowing protections.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

8 

Strategic Goals

Goal 3: Promote Quality

& Value

As the safety and soundness regulator of the System, FCA ensures the well-being and 

future of agricultural producers and rural communities. OIG is committed to promoting 

FCA’s quality of oversight and maximizing the value of funds invested in such oversight. 

The OIG performs the following actions in support of this goal:

• Creates benchmarks for improved Agency decision making

• Ensures the OIG and FCA are models for good government

• Produces OIG products that are timely, relevant, reasonable, and helpful

During this reporting period, the OIG completed a benchmarking study of information 

technology (IT) spending and use of contractors. The purpose of this benchmarking 

study was to determine the changes in IT spending and use of contractors over the 

past three years and compare FCA’s IT budget and use of contractors to other federal 

financial regulators. 

The OIG is continuously working to ensure compliance with standards, improve 

internal processes, and advance professional competencies. During this period, we 

completed an internal quality assurance review and continued to review and update 

our office directives. We put a priority on staff training to meet requirements for 

professional education and gain new skills.

OIG products are generally completed in six months or less. Our audit, inspection, and 

evaluation work is risk based to align with the top management and performance 

challenges at the Agency.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

9 

Strategic Goals

Goal 4: Advance FCA ́

s Future

The OIG continuously strives to advance excellence and innovation in our own 

organization and operations. 

The OIG employs the following actions in support of this goal:

• Recruits, retains, and empowers a diverse workforce

• Promotes leadership, vision, and expertise

• Leverages technology

The OIG continuously works to retain and empower a diverse workforce. Although the 

OIG did not recruit for positions during this reporting period, the IAA with TIGTA and 

cross-training opportunities in the IG community provide opportunities for diversity 

in our workforce. 

OIG staff assume leadership roles in the IG community by participating on various 

CIGIE committees, workgroups, and initiatives. Two senior auditors taught a class on 

interviewing techniques for CIGIE. Another auditor participated in the workgroup that 

planned the 40th Commemoration of the IG Act. The IG conducted several mediations 

for the sharing neutrals program in the government. All OIG staff maintain various 

professional certifications in different areas of expertise, including: auditing, IT 

auditing, accounting, investigations, fraud, law, and mediation. 

One example of the OIG leveraging technology is our revised OIG website page, which 

we revamped to increase the usability and transparency of our information for the 

public. In addition, the OIG continued its exploration of other software solutions to 

increase the efficiency of our audits, inspections, evaluations, and investigations. We 

are closely following the efforts of the CIGIE audit committee regarding obtaining 

group license fees for such automated solutions at a discount. We want to ensure that 

the benefits of any new software solution will justify the cost. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

10

Performance Measures 

The following discussion describes the performance measures of our office, as set forth 

in our Strategic Plan for FYs 2018-2019, and the actions we have taken to meet these

measures.

Measuring Our Performance

Performance 

Measure 

Actions Taken

Efficiencies Have been gained by using shared services with TIGTA.

Completion time 

of OIG work 

assignments

Has been appropriate based on the complexity or unique 

nature of each assignment. Most of our audit, inspection, and 

evaluation reports are completed within six months or less. All 

our required reports have been completed on time. We 

conducted two preliminary investigations and completed both 

within one month of receiving the initial complaint. We 

conducted one formal investigation and issued the report of 

investigation within five months of the initial complaints. 

Audit, inspection, 

and evaluation 

recommendations

Have been 100 percent accepted by the Agency and converted

to agreed-upon actions.

Complaints 

activity

Has increased significantly in this reporting period, indicating 

employees have confidence in the OIG and its ability to 

investigate wrongdoing while guarding their confidentiality.

Interaction with 

Congress

Continues with our semiannual reporting to Congress. Our 

congressional agricultural oversight committees in both the 

Senate and House had no questions or concerns about the 

most recent report.

Communication 

with the FCA 

Board and 

management

Is an ongoing priority of our office. We held quarterly briefings 

with each FCA Board Member and their executive assistants. 

We regularly communicate with FCA management through our 

audit, inspection, evaluation, and investigative work. We met 

with OE management and attended the all-staff OE conference 

this fall in Seattle to present the mission and philosophy of the 

OIG.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

11

Performance Measures 

Measuring Our Performance

Performance 

Measure 

Actions Taken

Aligning audit 

planning with 

FCA’s top 

management 

and 

performance 

challenges

Is important to ensure that our work is risk based and that it 

addresses the most significant challenges of the Agency. In this 

report, we cite the relevant management and performance 

challenge in discussing each audit, inspection, and evaluation.

Outreach 

efforts

Have included two quarterly issues of the dIG, our office 

newsletter with articles about what we do, how we do it, and 

why we do it, as well as examples of fraud, waste and abuse in 

government. We met with the OE management team where the 

IG and the investigator presented their perspectives on the 

roles of the OIG and investigator and answered questions. The 

IG and investigator made this same presentation at the all-staff 

OE conference this fall in Seattle.

Participation 

in CIGIE

Is an integral part of our office objectives. Every staff member 

is active on one or two CIGIE committees or initiatives, including 

participating in CIGIE’s training program and conducting peer 

reviews. Interacting with the wider IG community is a necessary

and beneficial part of our mission.

Training taken This reporting period included audit, investigative, IT, and legal

training. Staff members are cognizant of the required training 

they must take to keep up their skills and ensure that all their

training requirements have been met. 

Diversity of 

OIG staff 

when hiring 

opportunities 

arise

Is a goal of our office; however, we have had no hiring this 

reporting period. Our shared services agreement with TIGTA 

and cross-training initiatives in the IG community provide

opportunities to work with a diverse staff.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

12

Audits, Inspections, and Evaluations 

Summary

This reporting period, the OIG continued to provide FCA with high-quality products. 

We issued three inspection and evaluation reports, with a total of three agreed-upon 

actions with FCA management. We also have four reviews in progress. 

• The OIG found no significant problems, abuses, or deficiencies relating to the 

administration of programs and operations. 

• The OIG did not identify any questioned costs, unsupported costs, or 

disallowed costs during this reporting period.

The OIG conducts all audits in accordance with Government Auditing Standards issued by 

the Comptroller General of the United States for audits of federal organizations, programs, 

activities, and functions. We conduct inspections and evaluations in accordance with CIGIE’s

Quality Standards for Inspection and Evaluation. 

Copies of most OIG reports are available on our website, by contacting the OIG at (703) 

883-4030, or by email. We offer a free subscription service that provides automatic 

notification by email when a new report or other information is posted to the OIG website. 

Finally, we post all our public reports and information on Oversight.gov. Oversight.gov is a 

publicly accessible, searchable website containing the work of federal Offices of Inspectors 

General.

Reports Issued

Below is a listing of the audit, inspection, and evaluation reports issued during this 

reporting period. 

Table 1: Audit, Inspection, and Evaluation Reports Issued

Report Title

Number of 

Agreed-upon 

Actions/ 

Recommendations

Information Technology Benchmarking Study 0

Inspection of Physical Security in the Farm Credit Administration’s 

Sacramento Field Office

3

Inspection of Physical Security in the Farm Credit Administration’s 

Dallas Field Office

0

Total 3
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

13

Audits, Inspections, and Evaluations 

Reports Issued

Information Technology Benchmarking Study

Evaluation 

Justification

IT spending, including the use of IT contractors, has increased at 

FCA over the past few years. The purpose of this benchmarking 

study is to determine the IT budget changes over the past three 

years and compare FCA’s IT budget and use of contractors to 

other federal financial regulators.

Evaluation 

Objective

The objective of this evaluation is to compare FCA’s IT budget 

and use of contractors to other federal financial regulators.

Management 

Challenge

The OIG identified Information Technology as one of four top 

management and performance challenges at FCA. This challenge 

is the ability to leverage investments in IT while maintaining a 

secure environment.

While cybersecurity threats are increasing, FCA is increasingly 

reliant on IT software to identify and analyze potential risks from 

the sensitive financial data that the Agency receives from the 

System. Hence, it is imperative that FCA has the necessary IT tools 

and staff to protect its systems and data from cybersecurity 

threats and to operate more efficiently and effectively. At the 

same time, the Agency must be prudent and responsible with its 

spending. 

Conclusions Our benchmarking study reveals that the budget of FCA’s Office 

of Information Technology (OIT) has grown at a much higher 

percentage over the past three years than all other FCA office 

budgets. 

Of the benchmarked federal financial regulators, FCA has the 

smallest overall agency budget, IT budget, and number of 

employees. However, when compared to the IT budgets of the 

other federal financial regulators, FCA‘s IT budget, as a 

percentage of the Agency’s budget, falls in the middle of the 

benchmarked agencies, and its use of contractors was the 

lowest of all the other agencies.

This report does not contain any recommendations or agreedupon actions. Since the full report contains sensitive information 

about other agencies, the OIG released publicly a redacted 

version of the report. 

Milestones The Information Technology Benchmarking Study report was 

issued on September 6, 2018. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

14

Audits, Inspections, and Evaluations 

Reports Issued

Inspection of Physical Security in FCA’s Sacramento 

Field Office

Inspection 

Justification

Physical security controls safeguard FCA employees and assets. 

Physical security is unique in different locations and buildings, and 

the strongest controls cannot eliminate security risks. However, 

strong controls and preparedness can improve overall security. 

For this inspection, we reviewed the Sacramento field office. Our 

review focused on controls related to access, computers and other 

equipment, emergency preparedness, and personnel records.

Inspection 

Objective

The objective of the inspection was to determine the effectiveness 

of controls related to physical security in the Sacramento field 

office. 

Management 

Challenge

This inspection addresses the management challenge on Human 

Capital. This challenge entails FCA’s need to maintain a welltrained, sustainable workforce in the face of retirement 

eligibilities, workforce retention, and diversity, and the need to 

invest in its employees and their development. To address this 

management challenge, this inspection looked at physical security 

controls in the workplace. 

Conclusions We found controls were in place and generally effective. However, 

we identified opportunities to further improve physical security in 

the Sacramento field office. In response to our inspection, Agency 

management completed three actions that will improve physical 

security. The report contains sensitive information about FCA and 

potential vulnerabilities. Therefore, we did not release this report 

publicly.

Milestones We issued the final report, Physical Security in FCA’s Sacramento 

Field Office, on June 19, 2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

15

Audits, Inspections, and Evaluations 

Reports Issued

Inspection of Physical Security in FCA’s Dallas Field 

Office 

Inspection

Justification

Physical security poses a continuous challenge for federal 

agencies. The OIG initiated physical security inspections of FCA 

field offices during 2018. To date, we have completed inspections 

of the Denver, Bloomington, Dallas, and Sacramento field offices.

Inspection 

Objective

The objective of the inspection was to determine the 

effectiveness of controls related to physical security in the Dallas 

field office. 

Management 

Challenge

This inspection addresses the management challenge on Human 

Capital. This challenge entails FCA’s need to maintain a welltrained, sustainable workforce in the face of retirement 

eligibilities, workforce retention, and diversity, and the need to 

invest in its employees and their development. To address this 

management challenge, this inspection looked at physical 

security controls in the workplace. 

Conclusions We found controls were in place and generally effective in the 

Dallas field office. However, we identified opportunities to further 

improve physical security. The Agency initiated corrective actions 

based on the review and previous physical inspections. Therefore, 

we did not make any recommendations in the report. The report 

contains sensitive information about FCA and potential 

vulnerabilities. Therefore, we did not release this report publicly.

Milestones We issued the final report, Physical Security in FCA’s Dallas Field 

Office, on April 19, 2018. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

16

Audits, Inspections, and Evaluations 

In Progress

Inspection of Physical Security in FCA’s Headquarters

Inspection 

Justification

Physical security poses a continuous challenge for federal 

agencies. The OIG initiated physical security inspections of FCA 

field offices during 2018. 

Inspection 

Objective

The objective of the inspection is to determine the effectiveness 

of controls related to physical security in Headquarters. 

Management 

Challenge

This inspection addresses the management challenge on Human 

Capital. This challenge entails FCA’s need to maintain a welltrained, sustainable workforce in the face of retirement 

eligibilities, workforce retention, and diversity, and the need to 

invest in its employees and their development. To address this 

management challenge, this inspection looked at physical 

security controls in the workplace. 

Milestones Our draft report was issued in September 2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

17

Audits, Inspections, and Evaluations 

In Progress

Office of Examination Benchmarking Study

Evaluation

Justification

The Office of Examination is responsible for examining and 

supervising the System and uses examination staff to accomplish 

its mission. The purpose of this evaluation is to compare FCA to 

other federal financial regulators through a survey with questions 

about examination staff, locations, hiring, and supervision. 

Evaluation

Objective

The objective of this evaluation is to compare FCA’s examiner 

career structure and organization within the Office of Examination 

to other federal financial regulators.

Management 

Challenge

This inspection addresses the management challenge on the

Examination and Supervision Program. This challenge included 

identifying and addressing risks in the System through effective 

examination and supervision to ensure the System remains safe 

and sound. This evaluation will provide management with 

information about how other federal financial regulators’ 

examination staff structure and organization compare to FCA. 

Milestones We plan to issue our evaluation during the next reporting period. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

18

Audits, Inspections, and Evaluations 

In Progress

FY 2018 Evaluation of the Farm Credit 

Administration’s Compliance with the Federal 

Information Security Modernization Act of 2014 

(FISMA)

Evaluation

Justification

FISMA requires IGs or an independent external auditor to 

perform an annual evaluation of their agencies’ security program 

and practices. 

Evaluation

Objective

The objectives of this evaluation are to determine the 

effectiveness of FCA’s information security programs and 

practices and to provide the OIG with the ability to report the 

results to the Office of Management and Budget (OMB) and the 

U.S. Department of Homeland Security. 

Management 

Challenge

The OIG identified Information Technology as one of FCA’s top 

management and performance challenges in FCA’s FY 2017 

Performance and Accountability Report. This challenge is the 

ability to leverage investments in IT while maintaining a secure 

environment. The OIG performs an annual evaluation of FCA’s 

compliance with FISMA to address this management challenge.

Milestones Results of OIG assessments are reported to OMB through 

CyberScope, a web portal designed for federal agencies’ FISMA 

reporting. The FY 2018 annual reports are due by October 31, 

2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

19

Audits, Inspections, and Evaluations 

Audit of FCA’s Financial Statements Fiscal Year 2018

Audit

Justification

The Accountability of Tax Dollars Act of 2002 requires FCA to 

submit to Congress and OMB audited financial statements each 

fiscal year. The OIG contracted with Harper, Rains, Knight & 

Company, P.A. (HRK), an independent public accounting firm, to 

perform the audit of FCA’s financial statements for FY 2018. The 

OIG monitors the work of HRK. 

 Progress

Audit

Objective

The objective of the audit was for the auditors to express an 

opinion on FCA’s financial statements. 

In

Management 

Challenge

The financial statement audit is a required audit and is therefore 

not designed to address any specific FCA management and 

performance challenge. However, this audit indirectly addresses 

the management challenge on Organizational Structure and 

Governance, which entails FCA’s need to align its organizational 

structure, in part, to the goals and priorities of the FCA Board 

while remaining a strong safety and soundness regulator. 

Milestones The FY 2018 financial statement audit will be issued in November 

2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

20

Audits, Inspections, and Evaluations 

Agreed

-upon Actions

The Agency issued three reports during this reporting period with three agreed-upon 

actions. In addition, at the beginning of the period, eight carry-over actions were still 

open. As of September 30, 2018, two agreed-upon actions remained open. 

Before the commencement of and during this reporting period, there were no 

questioned costs, unsupported costs, disallowed costs, or recommendations that funds 

be put to better use for which no management decision had been made.

Table 2: Audit, Inspection, and Evaluation Agreed-Upon Actions

Report Title Date 

Issued

Carryover 

from 

Prior 

6-Month 

Period 

New 

During 

This 6-

Month 

Period 

Final 

Management 

Actions 

During This 

6-Month 

Period

Open on 

9/30/18

FCA’s Position 

Management and Job 

Evaluation Program

9/23/2016 1 0 1 0 

Physical Security in 

FCA’s Denver Field 

Office

9/29/2017 4 0 4 0 

FY 2017 Evaluation of 

FCA’s Compliance 

with FISMA

10/27/2017 2 0 0 2 

FCA’s Office of 

Secondary Market 

Oversight

3/20/2018 1 0 1 0 

Physical Security in 

FCA’s Dallas Field 

Office

4/19/2018 0 0 0 0 

Physical Security in 

FCA’s Sacramento 

Field Office

6/19/2018 0 3 3 0 

Information 

Technology 

Benchmarking Study

9/6/2018 0 0 0 0 

Total 8 3 9 2 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

21

Audits, Inspections, and Evaluations 

Open Agreed

-upon Actions

The following chart shows open agreed-upon actions for reports issued as of 

September 30, 2018. 

Table 3: Open Audit, Inspection, and Evaluation Agreed-Upon Actions

Report Title Date 

Issued

Agreed

-upon 

Action 

#

Summary of Agreed-upon Action

FY 2017 Evaluation of 

FCA’s Compliance 

with FISMA

10/27/2017 1 

2 

To OIT (not released publicly)1 

To OIT (not released publicly)

1

 

1 Protected by 44 U.S.C. 3555(f). 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

22

Other Reports 

Summary

This reporting period, the OIG issued three reports on the quarterly survey to the 

Chief Examiner and FCA Board. The reports summarize survey results and stakeholder 

opinions on the quality and issues involved in the examination function. Additionally, 

the OIG issued a management advisory on compensation. The OIG also completed 

our internal quality assurance review and an external peer review of the U.S. ExportImport Bank (EXIM) OIG’s inspection and evaluation organization. 

Survey of Farm Credit System Institutions

Survey 

Justification

The OIG administers a quarterly survey of System institutions 

regarding the quality and consistency of the Agency’s 

examination function, including the examiners’ performance. 

Survey 

Objective

The objective of the survey is to obtain feedback from System

institutions about FCA examiners and the examination process

without identifying the responding institutions. 

Management 

Challenge

The OIG identified the Examination and Supervision Program

as one of four top management and performance challenges at 

FCA. This challenge identifies and addresses risks in the System 

through effective examination and supervision to ensure the 

System remains safe and sound. 

Conclusions The consistent trend in numerical ratings and narrative 

comments indicates that the System has a positive view of the 

examination program and staff.

Milestones Each quarter the OE identifies numerous System institutions that 

could provide meaningful survey responses for that period. The 

OIG sends surveys to those institutions for the quarter.

During this reporting period, the OIG issued three reports to the 

FCA Board and Chief Examiner summarizing survey response 

data as follows:

• First Quarter FY 2018, issued April 10, 2018 – 8 out of 9 

institutions responded. 

• Second Quarter FY 2018, issued June 21, 2018 – 10 out of 12 

institutions responded. 

• Third Quarter FY 2018, issued September 28, 2018 – 14 out 

of 16 institutions responded. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

23

Other Reports 

Management Advisory on the Farm Credit 

Administration Compensation Policy

Justification The OIG completed an advisory memorandum to discuss the 

pay exception and grade and pay retention aspects of the 

Agency’s compensation policy. 

Objective The objective of the advisory was to discuss the Agency’s 

compensation policy and provide the FCA Board an analysis of 

certain compensation factors.

Management 

Challenge

The OIG identified Human Capital as one of four top 

management and performance challenges at FCA. This 

challenge is maintaining a well-trained, sustainable workforce 

while facing challenges in retirement eligibilities, workforce 

retention, and diversity. 

Conclusions FCA has compensation flexibilities granted under the Farm 

Credit Act of 1971, as amended. Although flexibilities within 

the compensation program are needed, the OIG found that the 

Agency may have opportunities to improve controls over the 

compensation process. These improvements could help ensure 

that pay exceptions and pay and grade retention policies are 

adequately justified, consistently and fairly applied, and in 

furtherance of FCA’s pay-for-performance compensation 

system. 

Milestones A final memorandum was issued to the Board on April 17, 2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

24

Other Reports 

Internal Quality Assurance Review

Justification The OIG completes an internal quality assurance review each 

year, as is outlined in our office’s internal directives, to identify 

systemic issues needing improvements and recommendations 

for corrective actions. 

Objective The objective of this review is to determine whether internal 

procedures were established, implemented, and operating 

effectively within the OIG.

Management 

Challenge

This review is part of the OIG’s internal quality assurance 

process and does not align with a management challenge. 

Conclusions While conducting this review, no systemic issues or weaknesses 

were noted. Our report did not make recommendations but

included four considerations to increase efficiency and 

effectiveness and improve operations. 

Milestones The final report was issued August 15, 2018.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

25

Investigations 

Summary

The OIG investigator has responsibility for developing and implementing an 

investigative program that furthers OIG’s goals. The investigator’s primary 

responsibilities include: 

• Investigating possible violations of criminal statutes relating to FCA’s programs 

and activities. 

• Investigating allegations of waste, fraud, abuse, mismanagement, or 

misconduct by FCA employees. 

• Interfacing with the Department of Justice on OIG-related criminal matters. 

• Coordinating investigations and OIG initiatives with other federal, state, and 

local investigative agencies and other OIGs through the Assistant IGs for 

Investigations Committee. 

• Protecting whistleblowers and providing whistleblower training.

Investigations cover a broad range of allegations concerning criminal wrongdoing or 

administrative misconduct affecting various FCA programs and operations. 

Investigations may be initiated because of allegations or referrals from: 

• FCA employees or contractors 

• Congress 

• OIG audits, inspections, or evaluations

• OIG Hotline 

• The public

• OIG’s proactive efforts directed at areas bearing a high potential for fraud, 

waste, abuse, and mismanagement

The OIG conducts all investigations in accordance with CIGIE’s Quality Standards for 

Investigations. Closing memoranda for OIG investigations are available on our website. 

This reporting period we processed 20 complaints, including five borrower rights-type 

complaints, which we referred to the OCPA or the Office of General Counsel (OGC). We 

conducted two preliminary investigations and one formal investigation. The formal 

investigation was based on complaints received during the prior reporting period. 

• The OIG had no reported allegations of whistleblower retaliation. 

• No investigative matters were referred to prosecutorial authorities that resulted 

in prosecutions or convictions. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

26

Investigations 

Investigations

Priorities The OIG is committed to conducting fair, thorough, and timely 

investigations. Our work products will be clear, focused, and 

factual reports of investigation. It is also our goal to guard the 

confidentiality of all with whom we interact in the investigative

process to the extent possible permitted by the law. 

The OIG renewed its shared services IAA with TIGTA for 

investigative support services for FY 2019. Our priorities are 

focused on enhancing our outreach to the Agency through 

training and townhall meetings, and updating our investigations 

manual, procedures, and files. 

Outreach This reporting period we presented to OE management and staff 

the role of the OIG, our approach to investigations, and ways to 

report suspected fraud, waste, abuse, and gross 

mismanagement. 

Complaint 

Activity

We received 20 complaints this reporting period as follows: 

• Five complaints were from System borrowers and were 

referred to the OCPA or the OGC. 

• Twelve complaints involved matters outside the 

jurisdiction of the OIG and were closed or referred to 

other federal agencies. A “no jurisdiction” response was 

sent to each of the complainants. 

• One complaint alleged a potential breach of FCA data by 

parties outside the Agency and was found to be 

unsubstantiated. 

• One complaint alleged the Agency did not properly 

respond to a borrower rights complaint. We conducted a 

preliminary investigation and found the complaint to be 

unsubstantiated, finding the Agency substantially 

followed policy and procedures in responding to the 

borrower rights complaint. 

• OIG received an anonymous complaint regarding dual 

compensation waivers being used for certain positions in 

the Agency. We conducted a preliminary investigation 

and found the complaint to be unsubstantiated, finding 

appropriate authorities were in place for the waivers.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

27

Investigations 

Investigative Activity

We conducted and closed one formal investigation concerning a senior government 

employee based on two complaints with similar allegations that we received during 

the prior reporting period. We investigated eight allegations concerning the 

performance of the subject’s official duties, including: creating a hostile work 

environment through harassment and retaliation, engaging in prohibited personnel 

practices, violating provisions of the Federal Travel Regulations, instructing staff to 

disregard the instructions of a contracting officer in a competitive procurement, and 

purchasing and abandoning IT software that amounted to a gross waste of Agency 

funds. One finding of potential criminal violations involving voucher reimbursements 

was declined by the U.S. Department of Justice on July 20, 2018. The OIG issued Report 

of Investigation (ROI) #18-01 on August 3, 2018 to management for consideration of 

administrative or disciplinary action. We requested a response within 90 days, which is 

due from the Agency on November 1, 2018. We did not disclose the findings of the 

investigation to the public. After we issued the ROI, we posted a closing memorandum 

on our website summarizing the allegations that we investigated.

The table below is a summary of investigative activity during the reporting period.

Table 4: Investigative Activity

A. Total number of investigative reports issued during the reporting 

period 1 

B. Total number of persons referred to the Department of Justice for 

criminal prosecution during the reporting period 1 

C. Total number of persons referred to state and local prosecuting 

authorities for criminal prosecution during the reporting period 0 

D. Total number of indictments and criminal informations during the 

reporting period that resulted from any prior referral to prosecuting 

authorities

0 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

28

Legislative and Regulatory Reviews

Summary

As required by section 4(a)(2) of the IG Act, the OIG routinely reviews existing and 

proposed legislation and regulations relating to programs and operations of FCA. 

The OIG makes recommendations concerning the impact of such law on the 

economy and efficiency in the administration of programs and operations or the 

prevention and detection of fraud, waste, abuse, and mismanagement. 

This past reporting period, the OIG continued to review and provide comments and 

analysis on existing and proposed cross-cutting legislation and regulations through 

our participation in the Legislation Committee and various CIGIE committees. 

Legislation

Through our participation in the Legislation Committee, we tracked various legislative 

initiatives, including IG testimonial subpoena authority; an appropriation for 

Oversight.gov and other related IT services; a bill aimed at improving the

government’s customer service; a bill requiring agencies to report information about 

open recommendations in their budget justifications; a proposal to require IGs to 

disclose subjects of ongoing investigations in their semiannual reports to Congress; 

a bill reauthorizing and amending the OIG whistleblower ombudsman position; and 

how IGs oversee and report on improper payments. We also tracked 

recommendations to reform the Program Fraud Civil Remedies Act.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

29

Legislative and Regulatory Reviews

FCA Board Approved Actions

• Final Rule on Farmer Mac Investment Eligibility (September 13, 2018)

• Revised Bookletter on Farm Credit Bank and Association Nominating 

Committees (September 13, 2018)

• FCA Revised FY 2019 and FY 2020 Budgets (September 5, 2018)

• Revised FCA Board Policy Statement on Equal Employment Opportunity and 

Diversity (September 4, 2018)

• FCA 2018 Abstract of the Unified Agenda of Regulatory and Deregulatory 

Actions and Fall 2018 Regulatory Project Plan (July 20, 2018)

• Proposed Rule on Eligibility Criteria for Farm Credit System Bank and 

Association Outside Directors (July 12, 2018)

• FCA Strategic Plan for FYs 2018-2023 (June 27, 2018)

• Final Rule on Farm Credit System Banks and Associations Investment Eligibility 

(May 10, 2018)

• Proposed Rule on Farm Credit System Banks and Associations Standards of 

Conduct (May 10, 2018)
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

30

Reporting and Outreach 

Congress

We had no interaction with Congress this reporting period.

IG Community

OIG staff members are encouraged to take part in organizations that contribute to the 

mission of the IG community and their individual professional development.

The IG is a member of CIGIE and serves on the CIGIE Legislation Committee and the 

Small and Unique Agency IGs working group. She attended the Annual CIGIE IG 

Conference on Leveraging Diverse Talents in a Changing Federal Environment in May

2018, which was held in Lancaster, Pennsylvania. The conference was educational and 

provided a welcoming forum to get to know other Inspectors General.

The senior auditors and investigator also participate in CIGIE workgroups. One auditor 

attends local Information Systems Audit and Control Association (ISACA) meetings and 

participates on CIGIE’s Audit Committee and the IT Subcommittee of the Federal Audit 

Executive Council. Another auditor is a member of the CIGIE Roundtable on Inspections 

and Evaluations and is an adjunct instructor for CIGIE’s Training Institute. Another auditor 

served as a member of the IG Act Commemoration Working Group. Our investigator 

participates in the Assistant IG for Investigations Committee. 

FCA

The OIG started a new outreach initiative by launching an internal, quarterly newsletter, 

the dIG, to FCA employees explaining the role of the OIG and how the OIG performs 

its work, including examples of fraud, waste, abuse, and mismanagement in 

government, and other topics. We issued two quarterly newsletters this reporting 

period. The IG also reports quarterly to the FCA Board and as needed.

The OIG participated in two new employee training sessions, met with the OE 

management team, and presented at the all-staff OE conference this September in 

Seattle. All presentations focused on the OIG mission and philosophy. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

31

Appendix A: FCA Organizational Chart 

FCA ORGANIZATIONAL CHART

*Reports to the Board for policy and to the CEO for administration. 

†Maintains a confidential advisory relationship with each of the Board members. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

32

Appendix B: Peer Review 

Summary

Periodically, the audit, inspection, evaluation, and investigation programs of OIGs are 

peer reviewed by external OIG members. The purpose of these external reviews is to 

provide an additional level of assurance that every OIG conducts its audits, 

inspections, evaluations, and investigations in compliance with applicable professional 

standards. This reporting period, the OIG completed an external peer review of the 

EXIM OIG’s inspection and evaluation program. 

Audit

Government Auditing Standards require an external peer review every three years. 

During this reporting period, the FCA OIG did not have an external peer review of 

its audit function. The last peer review of our audit operations was completed by 

the Federal Labor Relations Authority (FLRA) OIG in August 2016 for the year

ending on March 31, 2016. The FLRA OIG concluded that our system of quality 

control for the audit organization was suitably designed and complied with to 

provide reasonable assurance of performing and reporting in conformity with 

applicable professional standards in all material respects. We received the highest

rating of pass, and FLRA OIG did not make any recommendations for 

improvement.

The next audit peer review of our office is scheduled for the period ending March 31, 

2019. We did not complete any audit peer reviews of other OIGs during this reporting 

period.

Inspections &

Evaluations

Recently, CIGIE membership adopted a new peer review requirement for OIGs 

that perform inspections and evaluations in accordance with CIGIE’s Quality 

Standards of Inspection and Evaluation (Blue Book). One senior auditor assisted 

CIGIE in implementing this new requirement. The senior auditor is a member of 

the peer review implementation team. 

During this reporting period, we completed an inspection and evaluation peer 

review of the EXIM OIG. The review team included a lead from our office and a 

team member from the Corporation for National and Community Service OIG. 

The review team determined that the EXIM OIG’s policies and procedures 

generally met the seven Blue Book standards addressed in the external peer 

review. In addition, the two reports reviewed by the review team generally met 

the Blue Book standards and complied with EXIM OIG’s internal policies and 

procedures. The review team made five recommendations in the report, which are 

all closed based on actions implemented in response to the peer review. 

The first inspection and evaluation peer review of our inspection and evaluation 

function is scheduled for the period ending June 30, 2019.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

33

Appendix B: Peer Review

Investigation

s

CIGIE’s Qualitative Assessment Review Guidelines for Investigative Operations of 

Federal Offices of Inspector General established an independent external evaluation 

process for investigative operations. The objective of the investigation 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. 

FCA OIG is reinitiating the investigative peer review process of our investigation 

program. We have volunteered to participate in a peer review of our investigation 

function within the next few years.
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

34

Appendix C: Management Decisions 

Management Decisions

Status of 

Recommendations 

with No 

Management 

Decisions

Significant 

Revised 

Management 

Decisions

Agreement with 

Significant 

Management 

Decisions

Reports for Which 

No Agency 

Comment Was 

Returned Within 

60 Days

Instances Where 

the Agency 

Unreasonably 

Refused or Failed 

to Provide 

Information to the 

OIG or Attempted 

to Interfere with 

OIG Independence

All recommendations were agreed upon by management. 

Therefore, there were no recommendations more than six 

months old with outstanding management decisions. 

There were no significant revised management decisions 

during this reporting period. 

All recommendations were agreed upon by management. 

Therefore, there were no significant management 

decisions with which the OIG disagreed during this 

reporting period. 

There were no audit, inspection, or evaluation reports 

issued where comments were received after 60 days of 

providing the report to the Agency during this reporting 

period. 

There were no instances where the Agency unreasonably 

refused or failed to provide information to the OIG or 

attempted to interfere with the independence of the OIG 

during this reporting period. 
FCA OIG Semiannual Report to Congress

April 1, 2018—September 30, 2018

https://www.fca.gov/home/inspector.html

35

Appendix D: Index of Reporting Requirements 

SECTION REQUIREMENT PAGE

4(a)(2) Review of legislation and regulations 28-29

5(a)(1) Significant problems, abuses, and deficiencies 12

5(a)(2) Recommendations for corrective action 12-15

5(a)(3) Prior recommendations not yet implemented 20-21

5(a)(4) Matters referred to prosecutive authorities 27

5(a)(5) Information unreasonably refused or not provided 34

5(a)(6) List of audit, inspection, and evaluation reports issued 12

5(a)(7) Summaries of significant reports issued 13-19,

22-24

5(a)(8) Management decisions with respect to questioned costs 20

5(a)(9) Management decisions on recommendations that funds be put 

to better use

20

5(a)(10)(A) Audit reports for which no management decision has been 

made

34

5(a)(10)(B) Audit reports for which Agency comments were not received 

within 60 days of report issuance

34

5(a)(10)(C) Audit reports with unimplemented recommendations 20-21

5(a)(11) Significant revised management decisions 34

5(a)(12) Significant management decisions with which the IG disagreed 34

5(a)(13) Compliance of Agency financial management system 19

5(a)(14)(15) Peer reviews conducted of this OIG 32-33

5(a)(16) Peer reviews conducted by this OIG 32

5(a)(17)(18) Statistical tables for investigations and referrals 26-27

5(a)(19) Investigations involving a senior government employee where

allegations of misconduct were substantiated

25

5(a)(20) Instances of whistleblower retaliation 25

5(a)(21) Instances of attempts to interfere with IG independence 34

5(a)(22)(A) Closed audits, inspections, and evaluations not disclosed to the 

public

14-15

5(a)(22)(B) Closed investigations involving a senior government employee

not disclosed to the public

27

845 Significant contract audits required to be reported under National 

Defense Authorization Act for FY 2008 (Pub. L. 110-181)

N/A2

2 FCA OIG does not conduct contract audits. Therefore, we did not include this annex.
FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

Phone: Toll Free (800) 437-7322; (703) 883-4316

Fax: (703) 883-4059

E-mail: fca-ig-hotline@rcn.com

Mail: Farm Credit Administration

Office of Inspector General

1501 Farm Credit Drive

McLean, VA 22102-5090