~ IG 

Fann Credit Administration 

Office of Inspector General 

Farm Credit Administration 

Office of Inspector General 

Semiannual Report to Congress 

April 1, 2021 – September 30, 2021 
 

A()IG 

Farm Credit Administration 

Office of Inspector General 

FARM CREDIT ADMINISTRATION 

OFFICE OF INSPECTOR GENERAL 

SEMIANNUAL REPORT TO CONGRESS 

APRIL 1, 2021 – SEPTEMBER 30, 2021 
 

 

 

 

 

 

 

 

 

 

 

MESSAGE FROM THE INSPECTOR 

GENERAL 

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

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

Inspector General (OIG) for April 1, 2021 through September 30, 2021. 

While we close out yet another six months under the cloud of the COVID-19 pandemic, 

I can report another busy period for our audit, inspection, and evaluation functions. We 

concluded an inspection for which we surveyed FCA employees on the Agency’s 

response to the pandemic, identifying opportunities for FCA to provide additional 

information on workplace safety procedures and requirements. We also audited the 

Office of Secondary Market Oversight’s (OSMO) examination policies and procedures, 

making recommendations to increase consistency in the annual examination of the 

Federal Agricultural Mortgage Corporation and improve OSMO’s internal policies for 

identifying potential conflicts of interest. 

Nor did the ongoing pandemic prevent us from carrying out our other responsibilities. 

We diligently addressed all complaints received via the OIG hotline and reviewed and 

updated several internal policies and procedures to ensure the continuous 

improvement of our own operations. In view of our responsibility to keep Agency 

leadership and Congress fully and currently informed, we provided briefings to the FCA 

Board and staff of the House and Senate agricultural oversight committees. 

Finally, our office continued to make impactful contributions to the inspector general 

(IG) community. Throughout the reporting period, I chaired the Council of the 

Inspectors General on Integrity and Efficiency (CIGIE) Inspection and Evaluation 

Committee, while OIG staff brought their skills and experience to bear for the benefit 

of this and other CIGIE committees and workgroups. Notably, in June I and members 

of my staff presented at a town hall event on the revised CIGIE Quality Standards for 

Inspection and Evaluation. The virtual event, which was organized by OIG staff in 

coordination with others in the IG community, had over 700 participants across the 

government. I was also honored to serve on the CIGIE panel that makes 

recommendations on potential IG candidates to the President and agency heads. 

As we plan for a post-pandemic future, we are determined to take advantage of the 

lessons we have learned working in a remote environment. We look forward to 

employing the tools and flexibilities identified these past two years to provide the 

highest quality independent and objective oversight of FCA. 

Wendy R. Laguarda

Inspector General 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 i 
 

ACRONYMS & 

ABBREVIATIONS 

AIGAIE Assistant Inspector General for Audits, Inspections, and 

Evaluations 

CIGIE Council of the Inspectors General on Integrity and Efficiency 

E.O. Executive Order 

Farm Credit Act Farm Credit Act of 1971, as amended 

Farmer Mac Federal Agricultural Mortgage Corporation 

FCA (or Agency) Farm Credit Administration 

FISMA Federal Information Security Modernization Act of 2014 

FY Fiscal Year 

GAO U.S. Government Accountability Office 

I&E Inspection and Evaluation 

IG Inspector General 

IG Act Inspector General Act of 1978, as amended 

OE Office of Examination 

OIG Office of Inspector General 

OMB U.S. Office of Management and Budget 

OSMO Office of Secondary Market Oversight 

PIIA Payment Integrity Information Act 

Pub. L. Public Law 

System Farm Credit System 

U.S. United States 

U.S.C. United States Code 

ii Farm Credit Administration | Office of Inspector General 
TABLE OF 

CONTENTS 

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

Acronyms & Abbreviations.....................................................................................................................ii 

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

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

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

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

Summaries of Reports Issued........................................................................................................... 7 

Recommendations Made During the Reporting Period ........................................................ 9 

In Progress.............................................................................................................................................11 

Investigations ............................................................................................................................................12 

Complaint Activity ..............................................................................................................................12 

Summaries of Investigations...........................................................................................................13 

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

Outreach, Collaboration, & Other Initiatives.................................................................................15 

FCA Employees ....................................................................................................................................15 

Congress.................................................................................................................................................15 

Inspector General Community.......................................................................................................15 

Reviews of Proposed Legislation and Regulations................................................................. 16 

Internal Operations ............................................................................................................................16 

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

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

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

Appendix IV: Reports with Funds For Better Use.........................................................................21

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

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

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 iii 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

BACKGROUND 

The Farm Credit System 

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

borrower-owned cooperative financial institutions and service organizations. A 

government-sponsored enterprise, the System is designed to better the income and 

well-being of farmers, ranchers, and rural America by providing a safe and reliable 

source of credit and related financial services. 

As of July 1, 2021, the System consisted of three farm credit banks, one agricultural 

credit bank, one federal land credit association and 66 agricultural credit associations 

that primarily make loans to agriculture in all 50 states and Puerto Rico, as well as six 

service corporations that provide administrative, technology-related, and other support 

services to certain System entities and eligible borrowers. The System raises funds by 

selling securities in the national and international money markets through the Federal 

Farm Credit Banks Funding Corporation. 

The System also includes the Federal Agricultural Mortgage Corporation (Farmer Mac), 

a stockholder-owned, federally chartered instrumentality. Created in 1988, Farmer Mac 

provides a secondary market for agricultural real estate mortgage loans, rural housing 

loans, and rural utility cooperative loans. Farmer Mac is publicly traded and issues its 

own debt securities. 

The Farm Credit Administration 

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

responsible for ensuring that the System remains a dependable source of credit for 

agriculture and rural America. Authorized by the Farm Credit Act of 1971, as amended 

(Farm Credit Act),

1 FCA ensures the safety and soundness of System institutions by 

issuing policies and regulations, and by regularly examining System institutions to 

assess compliance with applicable laws and regulations. FCA has approximately 300 

full- and part-time employees distributed across five offices nationwide. 

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

President, with the advice and consent of the Senate. The Chair of the Board—who is 

designated by the President and serves in that role until the end of the Chair’s term— 

also serves as the Agency’s Chief Executive Officer. During the reporting period, the 

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

The Office of Inspector General 

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

task of providing independent and objective oversight of FCA programs and 

operations. It carries out this responsibility as authorized by and in accordance with the 

Inspector General Act of 1978, as amended (IG Act),2 by conducting and supervising 

audits, inspections, evaluations, and investigations; promoting economy and efficiency; 

1 12 U.S.C. § 2001 et seq. 

2 5 U.S.C. app. 

1 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

 

 

 

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

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

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

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

general supervision of the FCA Board, neither the Board nor any other Agency official 

may prevent or prohibit the IG from carrying out an oversight activity that the IG 

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

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

status. This independence is necessary to ensure that OIG products meet the highest

standards of objectivity and credibility. 

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

Reporting to the IG are the Assistant Inspector General for Audits, Inspections, and 

Evaluations (AIGAIE), the Investigator, and the Counsel to the IG. The AIGAIE supervises 

the audit staff and oversees the audit, inspection, and evaluation functions. 

The Council of the Inspectors General on Integrity and Efficiency 

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

and Efficiency (CIGIE). Composed of the federal Inspectors General and certain other 

federal officials, CIGIE was established to address cross-agency issues of integrity, 

economy, and effectiveness and to improve the professionalism and effectiveness of 

OIG personnel. OIG staff regularly participate on CIGIE committees and initiatives, as 

discussed in this report. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 2 
 

 

 

STRATEGIC 

PLAN 

In September 2019, the OIG adopted a five-year strategic plan for fiscal years (FYs) 2020 

to 2024. Revised in 2021, the plan details the vision, mission, values, goals, and 

objectives of the OIG in carrying out its responsibilities under the IG Act. 

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

Vision 

Harvesting Change 

Mission 

To provide independent oversight to promote economy, efficiency, and effectiveness, 

and prevent and detect fraud, waste, and abuse in Farm Credit Administration programs 

and operations 

Values 

Objectivity, Integrity, Relevance, and Respect 

Goals 

1) Promote Economy and Efficiency 

2) Prevent and Detect Fraud, Waste, and Abuse 

3) Strengthen Internal and External Relationships 

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PERFORMANCE 

MEASURES 

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

several measures against which the OIG assesses its performance. The following 

describes some of the OIG’s actions during the FY 2021 that were relevant to those 

performance measures. 

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

and management. 

In September 2020, the OIG published an audit, inspection, and evaluation plan for FYs 

2021 and 2022. A plan for FYs 2022 and 2023 was published in October 2021. 

Complete products in an average time of six months. 

The OIG completed six audit, inspection, and evaluation projects in an average time of 

174.8 days, under six months (182.5 days). Excluding matters performed under contract 

by external firms, the OIG completed four projects in an average time of 165.8 days. 

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

professional standards and office policies and procedures. 

On July 21, 2021, the OIG completed an internal quality assurance review of its audit, 

inspection, and evaluation functions. 

Make recommendations, as necessary, to management and monthly track 

recommendation status until closure. 

The OIG made nineteen recommendations during FY 2021. The OIG tracked the status 

of those recommendations on an ongoing basis and reported open recommendations 

to the FCA Board on a monthly basis. To aid in the tracking and reporting of 

recommendations, this year saw the implementation of a new electronic 

recommendation follow-up system, developed with the assistance of the FCA Office of 

Information Technology. 

Comply with mandatory training requirements and maintain professional 

certifications. 

All OIG staff remained on track to meet training requirements and maintain 

certifications as required by OIG policy and relevant professional standards. 

Promote diversity, equity, inclusion, and accessibility. 

In September 2021, this measure was updated to address equity and accessibility. 

During FY 2021, the OIG endeavored to improve office awareness and consciousness 

of diversity, equity, inclusion, and accessibility issues through training and internal 

discussions. As part of this initiative, OIG staff members presented topics of interest to 

them, including the impacts of the COVID-19 pandemic on women’s employment, 

eliminating workplace stigmas surrounding dyslexia, the contributions of veterans, 

black farm ownership in the United States, the impacts of government action on 

segregation, and transgender discrimination. 

OIG personnel also promoted these subjects by involvement in the CIGIE Diversity, 

Equity, and Inclusion Work Group, established in 2021 to affirm, advance, and augment 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 4 
 

 

 

 

 

CIGIE’s commitment to promote a diverse, equitable, and inclusive workforce and 

workplace environment throughout the IG Community. 

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

two business days of receipt. 

In September 2021, this measure was updated to clarify the expectation that complaints 

be initially evaluated within two business days. Of 46 complaints received during 

FY 2021, the OIG initially evaluated and acknowledged (or, where acknowledgement 

was not possible, acted upon) 44 complaints (95.7%) within two business days of 

receipt. 

Monthly track the status of allegations and investigations to ensure timely

actions. 

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

reported their status to the FCA Board. 

Perform or undergo annual reviews to ensure investigative activities are 

conducted in accordance with quality standards and internal policies and 

procedures. 

In September 2021, this performance measure was modified to require annual reviews 

of investigative activities, rather than regular reviews of particular investigations. In 

order to meet this measure going forward, the OIG’s investigations manual has been 

updated to require annual quality assurance reviews in years where the OIG does not 

receive an external peer review. 

Maintain a hotline from a source independent of the Agency. 

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

through a commercial provider. 

Promote awareness of hotline avenues. 

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

website, on the back cover of OIG reports, and during presentations to FCA employees. 

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

mismanagement, and whistleblower protections. 

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

employees, through three virtual town hall meetings, during meetings with new Agency 

supervisors, and in the OIG’s quarterly intra-agency newsletter. 

Monthly track reviews of relevant existing or proposed legislation and

regulations. 

In September 2021, this measure was updated to require monthly tracking of reviews 

of legislation and regulations, rather than timely review and comment. This modified 

measure will be addressed in future years’ reports. As discussed later in this report, the 

OIG commented upon legislation, as appropriate, through the CIGIE Legislation 

Committee. 

5 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

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

effectiveness of the Agency’s examination program. 

With the onset of the COVID-19 pandemic and related adjustments to FCA’s 

examination activities, the OIG paused its regular surveys of System institutions in April 

2020 but notified System institutions that the OIG remained available to hear any 

concerns about the examination process. The OIG resumed the survey process in May 

2021, with two new questions concerning the efficiency and effectiveness of 

communications during remote examinations. 

Annually conduct at least four outreach initiatives with employees. 

During FY 2021, the OIG conducted outreach to FCA employees through presentations 

to new employees and the issuance of an intra-agency newsletter. Additionally, in 

March 2021, the OIG held three virtual town hall meetings open to all FCA employees. 

These meetings were designed to demystify the OIG and elicit discussion about the 

office’s oversight work. 

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

reporting period. 

During FY 2021, the OIG transmitted its Semiannual Reports to Congress to the FCA

Board on April 29, 2021 and October 30, 2019, respectively. 

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

In June, the OIG provided virtual briefings to majority and minority staff of the House 

and Senate agricultural oversight committees. 

Post all audit, inspection, and evaluation reports within three business days of

issuance to the FCA Board. 

All final audit, inspection, and evaluation reports issued during FY 2021 were posted to 

the OIG’s website and to Oversight.gov within three business days of issuance to the 

FCA Board. 

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

The IG provided virtual briefings to each FCA Board member on a quarterly basis. 

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

In September 2021, this measure was updated to clarify the frequency of participation 

required. As discussed in greater detail later in this report, OIG personnel participated 

extensively in CIGIE committees and work groups throughout FY 2021. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AUDITS, INSPECTIONS, AND 

EVALUATIONS 

The OIG regularly completes audits, inspections, and evaluations of FCA programs and 

operations. In so doing, OIG personnel seek to provide timely, credible, and relevant 

information to Agency leadership, Congress, other stakeholders, and the general public. 

FCA OIG audits are performed in accordance with the Government Auditing Standards 

issued by the U.S. Government Accountability Office (GAO), while inspections and 

evaluations adhere to the CIGIE Quality Standards for Inspection and Evaluation. 

In planning its audits, inspections, and evaluations, the OIG employs a risk-based 

approach that accounts for prior oversight work, the control environment, input from

the FCA Board and senior management, statutory requirements, and resources. For

more information and to learn about future OIG work, please see the audit, inspection, 

and evaluation plan for FYs 2022 and 2023. 

Reports issued may be found on the OIG website within three business days of issuance 

to the FCA Board. To receive a notification when a new report is published, please 

subscribe to the OIG mailing list. Reports are also posted on Oversight.gov, a 

consolidated repository for the oversight work of federal inspectors general. 

Oversight.gov allows users to sort, search, and filter the site’s database to find reports 

of interest. Users can receive notifications when new reports are added to Oversight.gov 

by following CIGIE’s Twitter account, @OversightGov. 

Summaries of Reports Issued 

The OIG issued two reports and made five recommendations for corrective action 

during the reporting period. The reports are summarized below. 

The Office of Secondary Market Oversight’s

Examination Policies and Procedures 

A-21-01 

Unique among System institutions, Farmer Mac is a government-sponsored enterprise 

with the mission of providing a secondary market for a variety of loans made to 

borrowers in rural America. The OIG has recognized oversight of Farmer Mac as one of 

the most serious management challenges facing the Agency. Within FCA, the Office of 

Secondary Market Oversight (OSMO) is tasked with the examination, regulation, and 

general supervision of Farmer Mac. 

The Farm Credit Act requires that FCA, through OSMO, examine the financial 

transactions of Farmer Mac no less than once each year. The objective of this audit was 

to determine whether OSMO’s examination policies and procedures are documented 

and implemented. 

The OIG found that OSMO had limited documented policies and procedures for the 

areas unique to Farmer Mac examination work. While OSMO had directives addressing 

various aspects of its oversight of Farmer Mac, those directives lacked guidance on 

conducting the examination. According to OSMO officials, staff performing the Farmer 

Mac examination follow procedures established by the Office of Examination (OE) and 

use the FCA Examination Manual as guidance, as applicable. While the FCA Examination 

Manual provides a base of procedures, criteria, and guidance, it is maintained by OE, 

7 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

which is responsible for the supervision of System institutions other than Farmer Mac. 

Consequently, the FCA Examination Manual contains steps and references that are not 

applicable to Farmer Mac and does not include OSMO-specific procedures. To ensure 

accuracy and consistency in OSMO’s examination practices, the OIG identified a need 

for OSMO to document its reliance on the FCA Examination Manual, those areas that 

are not applicable to Farmer Mac, and OSMO examination steps that the FCA 

Examination Manual does not address. 

Additionally, a review of certain unique examination activities found that OSMO 

generally implemented its examination processes. Despite a lack of formal policies and 

procedures for the loan review process, the OIG reviewed OSMO workpapers and 

determined that examiners completed certain aspects of the exam that were unique to 

Farmer Mac. 

The OIG also tested OSMO’s implementation of policies and procedures that serve to 

identify potential conflicts that individuals working on a rotational assignment in OSMO 

may have as a result of work on examinations of other System institutions. The OIG 

identified opportunities to improve controls over the conflict of interest certification 

process, as OSMO lacked procedures to ensure that individuals completed certification

forms as required. The OIG also noted that OSMO’s directive did not mandate 

conflict-of-interest forms be completed before performing Farmer Mac examination 

work, resulting in inconsistencies in the timing of the process and undermining the 

forms’ purpose. 

Over the course of the audit, OSMO began to address concerns identified by the OIG, 

including by drafting and implementing written guidance for its examination process 

and updating its conflict-of-interest process. 

The OIG made four recommendations for corrective action, all of which were agreed to 

by FCA. 

The audit report was issued on September 24, 2021. 

Survey of FCA Employees on COVID-19

I-21-02 

In March 2020, the World Health Organization declared COVID-19 a global pandemic. 

That same month, FCA took steps to protect employees, entering a mandatory telework 

status for employees across the Agency’s five offices. From that point and throughout 

this inspection, the Agency generally remained in a full-telework status, with limited 

exceptions for essential staff. In July 2020, FCA began allowing employees to work from 

their offices with supervisory approval and assurances that the employee had not been 

diagnosed with, had symptoms of, or been exposed to others diagnosed with COVID19. 

On January 20, 2021, the President signed Executive Order (E.O.) 13991, directing 

executive agencies to take immediate action to require compliance with Centers for 

Disease Control and Protection guidelines on mask-wearing, maintaining physical 

distance, and other public health measures. E.O. 13991 was followed shortly by 

implementing guidance from the U.S. Office of Management and Budget (OMB), which 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 8 
 

 

 

 

 

 

 

 

 

 

 

 

provided model principles intended to assist agencies in building tailored COVID-19 

workplace safety plans. 

The objective of this inspection was to conduct a survey of FCA employees on safety 

measures and other actions implemented by the Agency in response to COVID-19. The 

OIG developed a seventeen-question survey based on guidance set forth in E.O. 13991 

and implementing OMB guidance. The survey was administered from March 3 to 10, 

2021, using a web-based platform that allowed for employees’ responses to be 

submitted anonymously. 

225 of 311 eligible FCA employees completed the survey, equating to a 72 percent

response rate. Overall, the results showed that employees believed the Agency took 

positive action in response to the COVID-19 pandemic. 72 percent of respondents 

indicated that they had not worked at their assigned worksite since the beginning of 

the implementation of mandatory telework in March 2020. Of those employees who 

reported having been to their assigned worksite, 87 percent indicated that they had not 

observed incorrect mask-wearing, lack of social distancing, non-limited occupancy, or

other sanitation issues. Employees generally indicated that they had the appropriate 

resources to telework and that they had been able to perform all of their job 

responsibilities remotely. 

Survey results also identified opportunities to provide additional communication to 

Agency employees. Most commonly, respondents expressed a desire for clarity on 

workplace safety procedures and requirements, including those related to maskwearing and social distancing and reporting potential COVID-19 exposures. 

Respondents also selected maximizing telework, flexible scheduling, and cleaning and 

sanitation as important factors when offices reopen. 

In April 2021, after the survey was completed, FCA distributed a draft plan for returning

to the workplace to agency employees. The draft plan addressed safety protocols for

employees across four operating status phases, including—among other things— 

telework and occupancy limits, travel, mask-wearing, physical distancing, and contact 

tracing. However, the OIG noted certain subjects where additional detail would be 

needed to address concerns expressed by survey respondents. 

The OIG made one recommendation for corrective action, which was agreed to by FCA. 

The inspection report was issued on June 9, 2021. 

Recommendations Made During the Reporting Period 

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

period. 

9 Farm Credit Administration | Office of Inspector General 
Table 1 

Report Recommendation 

The Office of 

Secondary Market

Oversight’s

Examination 

Policies and 

Procedures 

1 The Office of Inspector General recommends the Office of 

Secondary Market Oversight document those parts of the 

Farm Credit Administration Examination Manual that do 

not apply to the examination of the Federal Agricultural 

Mortgage Corporation. 

2 The Office of Inspector General recommends the Office of 

Secondary Market Oversight document examination 

policies and procedures unique to the examination of the 

Federal Agricultural Mortgage Corporation. 

3 The Office of Inspector General recommends the Office of 

Secondary Market Oversight expand the conflict of 

interest guidance in Directive 3 to require examiners to 

complete the conflict of i nterest form before engagi ng in 

examination activities. 

4 The Office of Inspector General recommends the Office 

of Secondary Market Oversight develop internal controls 

to ensure examiners complete the conflict of interest 

form according to guidance 

Survey of FCA 

Employees on 

COVID-19 

1 The Office of Inspector General recommends the Office of 

the Chief Operating Officer distribute further 

communications to employees to explain: 

• when it is necessary to be physically present during 

telework operating statuses; 

• how mask-wearing and other required workplace 

safety measures di ffer in Farm Credit Administration 

space and non-Farm Credit Administration space; 

• trends used in considering the Agency’s operating 

status; 

• future remote work arrangements and expectations; 

• specific procedures for when and whom to contact

regarding a suspected or confirmed coronavirus 

disease 2019 (COVID-19) diagnosis that affects the 

workplace; 

• specific procedures for official travel decisions and 

following Centers for Disease Control and Prevention 

guidelines after personal travel; 

• symptom monitoring procedures; and 

• specific procedures for quaranti ne and self-isolation 

after a suspected or confi rmed COVID-19 diagnosis 

or close contact. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 10 
 

 

In Progress 

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

reporting period. 

Audit of the Farm Credit Administration’s Financial Statements 

Fiscal Year 2021 

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

financial statements to Congress and OMB. Those financial statements must be audited 

by the IG or an independent external auditor, as determined by the IG. The OIG has 

contracted with an independent public accounting firm to perform this audit for 

FY 2021. The OIG is monitoring the work of the firm. 

Audit of the Farm Credit Administration’s Compliance with the 

Federal Information Security Modernization Act

Fiscal Year 2021 

The Federal Information Security Modernization Act of 2014 (FISMA) requires that the 

OIG annually evaluate FCA’s information security program and practices to determine 

their effectiveness. The OIG has contracted with an independent public accounting firm 

to conduct the FISMA review for FY 2021. In accordance with guidance issued by OMB 

and the U.S. Department of Homeland Security, the firm is assessing FCA’s performance 

with respect to nine domains: risk management, supply chain risk management, 

configuration management, identity and access management, data protection and 

privacy, security training, information security continuous monitoring, incident 

response, and contingency planning. The OIG is monitoring the work of the firm. 

Inspection of the Farm Credit Administration’s Property Management 

FCA has a property management program to ensure integrity, accuracy, and effective, 

timely accountability of personal property as it moves through its lifecycle. The 

objective of this inspection is to determine if FCA has implemented an adequate 

process to ensure accuracy in the property management system and adherence to 

internal policies and procedures. 

11 Farm Credit Administration | Office of Inspector General 
INVESTIGATIONS 

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

operations that the IG determines to be necessary or appropriate. The range of matters 

falling within the OIG’s investigative purview is expansive, encompassing potential 

violations of law, rules, or regulations; mismanagement; abuse of authority; and more. 

Investigative activities may be initiated upon allegations or referrals received from a 

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

congressional committees, other agencies, System institutions, or members of the 

public. The OIG may also investigate potential fraud, waste, abuse, and mismanagement 

identified through OIG audits, inspections, and evaluations. 

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

timely, clear, and credible, and to guard the identities of those who provide information 

to the OIG. All investigations are carried out in accordance with the CIGIE Quality 

Standards for Investigations. 

Table 2 summarizes major investigative activity during the reporting period. 

Table 2 

Investigative reports issued3 0 

Persons referred to the U.S. Department of Justice for criminal 0 

prosecution 

Persons referred to state and local prosecuting authorities for criminal 0 

prosecution 

Indictments and criminal informations that resulted from any prior 0 

referral to prosecuting authorities 

Metric Number 

Complaint Activity 

The OIG maintains a hotline that allows FCA employees and others to confidentially 

report potential fraud, waste, abuse, or mismanagement via telephone, email, or fax. 

The office also accepts complaints by mail and in-person.4 Table 3 shows the OIG’s 

response to complaints received during the reporting period. 

Table 3 

Investigations opened 0 

Closed after review with no further specific investigative action 21 

Referred to FCA program manager 4 

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

Under review at the end of the reporting period 0 

Action Taken Number 

Total 25 

3 This metric does not include memoranda memorializing the closure or referral of complaints. 

4 Due to the COVID-19 pandemic, the OIG has temporarily limited the available methods to 

make complaints to telephone and email. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 12 
Summaries of Investigations 

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

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

13 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

 

 

 

 

 

 

O

 

THER 

REPORTS AND 

REVIEWS 

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

evaluation, or investigation. These projects are typically undertaken in accordance with 

a statutory requirement, for quality assurance purposes, or to otherwise provide 

comprehensive oversight of FCA programs and operations. Below are summaries of 

such reviews that were completed during the reporting period. 

The Farm Credit Administration’s Compliance with the

Payment Integrity Information Act for Fiscal Year 2020 

Enacted in March 2020, the Payment Integrity Information Act of 2019 (PIIA) updated 

and replaced predecessor laws requiring agencies to identify and report on programs 

and activities that may be susceptible to significant improper payments. The PIIA 

mandates that each OIG annually review its respective agency’s improper payments 

reporting to determine whether it adhered to PIIA requirements and implementing 

OMB guidance. 

The OIG found FCA’s improper payments reporting to be compliant with applicable PIIA 

requirements for FY 2020. Specifically, the Agency published improper payments 

information in the Agency’s most recent Performance and Accountability Report, 

posted that report to the Agency’s website, and conducted statutorily required risk 

assessments within the previous three years. Because FCA determined all programs and

activities to be low-risk and not susceptible to significant improper payments, other 

PIIA requirements were not applicable to the Agency in FY 2020. 

On May 17, 2021, the OIG transmitted its review to the FCA Board and appropriate 

oversight bodies as required by the PIIA and OMB guidance. 

2021 Internal Quality Assurance Review 

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

and evaluation functions to determine whether OIG procedures were established, 

implemented, and operating effectively. The 2021 review determined that internal 

policies and procedures were effective and followed for audits, inspections, and 

evaluations issued between September 1, 2020, and June 30, 2021. This review noted 

no systemic issues or weaknesses and therefore made no recommendations. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 14 
 

 

 

 

 

 

 

 

 

 

 

OUTREACH, 

COLLABORATION, & 

OTHER INITIATIVES 

FCA Employees 

The cooperation of FCA employees is essential to all aspects of OIG oversight. 

Accordingly, the OIG has several ongoing initiatives geared toward educating FCA 

employees on the OIG’s mission and authorities. These include a quarterly intra-agency 

newsletter, the dIG, which spotlights the office’s functions and provides recent 

examples of OIG oversight products governmentwide. The OIG also participates in 

orientation trainings for new FCA employees and distributes posters to promote 

awareness of the OIG hotline. 

Congress 

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

informed about problems and deficiencies relating to FCA programs and operations, 

the OIG endeavors to respond expeditiously to all congressional requests and to 

periodically brief oversight committees on recent OIG activity. In June, the IG provided 

briefings on OIG activities to majority and minority staff from both the Senate 

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

Agriculture. 

Inspector General Community 

The OIG is an active member of the IG community, with staff lending their efforts and 

expertise to the work of various CIGIE committees and initiatives. 

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

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

Committee maintains professional standards for inspections and evaluations, heads the 

development of protocols for reviewing cross-agency management issues, and 

oversees the inspection and evaluation peer review process. This reporting period, OIG 

personnel presented at a virtual CIGIE town hall on the recently revised CIGIE Quality 

Standards for Inspection and Evaluation, an event that drew approximately 700 

participants from across the federal government. As Chair of the I&E Committee, IG 

Laguarda also served on the CIGIE Executive Council, which assists in governance of 

CIGIE. 

The IG also remained a member of the CIGIE Legislation Committee and the CIGIE IG 

candidate panel. The Legislation Committee fosters relationships with Congress, 

represents the IG community’s interests on legislative initiatives, and keeps OIGs 

apprised of pertinent legislative developments. The IG candidate panel reviews 

potential IG candidates and makes recommendations to the appropriate appointing 

authorities—the President or agency head. 

In addition to their involvement in the Legislation and I&E Committees, OIG staff 

participated in the CIGIE Audit Committee, the Small and Unique IG working group, the 

Council of Counsels to the Inspectors General, the Assistant Inspectors General for 

Investigations Subcommittee, the Whistleblower Protection Coordinators working 

group, and the CIGIE Diversity, Equity, and Inclusion working group. 

15 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

 

 

Reviews of Proposed Legislation and Regulations 

The OIG reviews existing and proposed legislation and regulations relating to FCA 

programs and operations. When appropriate, the OIG makes recommendations 

regarding the impact of such legislation or regulations on economy or efficiency or the 

prevention and detection of fraud, waste, and abuse. During the reporting period, the 

OIG reviewed several bills and proposed regulations related to FCA or IG authorities, 

including legislation intended to bolster IG independence and enhance IGs’ subpoena 

authority. The OIG provided comments on proposed legislation to the CIGIE Legislation 

Committee. 

Internal Operations 

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

reporting period, the OIG completed updates to several of its internal policies and 

procedures, ranging from the OIG’s investigations and audit, inspection, and evaluation 

manuals to directives on professional development and the OIG’s surveys of System

institutions. As noted above, the OIG also revised its strategic plan to, among other 

things, reflect the ongoing COVID-19 pandemic and make OIG performance measures 

more useful and informative. Finally, in accordance with the OIG’s internal enterprise 

risk management program, the OIG in April revised its risk profile to ensure its 

continued relevance and effectiveness. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 16 
 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX I: 

PEER 

REVIEWS 

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

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

provided below. 

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

website. Reports of peer reviews conducted by the FCA OIG may be located on the 

websites of the reviewed OIGs. 

Audit 

The GAO Government Auditing Standards require any organization conducting audits 

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

every three years. These peer reviews may conclude in a rating of pass, pass with 

deficiencies, or fail. A rating of pass signifies that the audit organization’s system of 

quality control has been suitably designed and complied with to provide the 

organization with reasonable assurance of performing and reporting in conformity with 

applicable professional standards and legal and regulatory requirements in all material 

respects. 

The FCA OIG’s audit function was not subject to peer review during the reporting 

period. The most recent peer review was completed by the National Endowment for 

the Humanities OIG on September 13, 2019. The FCA OIG received a rating of pass and 

the final report made no recommendations for corrective action. 

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

Inspection and Evaluation 

Under guidance initially adopted by CIGIE in January 2017, each OIG performing 

inspections or evaluations in accordance with the CIGIE Quality Standards for Inspection 

and Evaluation is required to undergo an external peer review every three years. During 

the first three-year cycle, peer review reports did not include an overall rating (such as 

pass, fail, compliant, or non-compliant), but included a conclusion as to whether the 

reviewed OIG adhered to specific CIGIE standards and the OIG’s internal policies and 

procedures for inspection and evaluation work. 

The FCA OIG’s inspection and evaluation function was not subject to peer review during 

the reporting period. The most recent peer review was completed by a team composed 

of personnel from the U.S. Equal Employment Opportunity Commission and U.S. 

Department of the Treasury OIGs on December 17, 2019. The final report concluded 

that FCA OIG inspection and evaluation policies met all standards addressed and found 

that the OIG reports reviewed adhered to standards and the OIG’s internal policies and 

procedures. The report made no recommendations for corrective action. 

The FCA OIG did not conduct any inspection and evaluation peer reviews during the 

reporting period. 

17 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

Investigation 

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

Offices of Inspector General establish an independent external evaluation process for 

investigative operations. The objective of an investigative peer review is to determine 

whether internal control systems are in place and operating effectively to provide 

reasonable assurance that an OIG’s investigative operations comply with CIGIE’s Quality 

Standards for Investigations. Reviewed OIGs are assessed a rating of compliant or noncompliant. While the guidelines do not mandate that OIGs without statutory law 

enforcement authority—like the FCA OIG—undergo investigative peer reviews, they 

encourage voluntary participation. 

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

The OIG’s investigative function is scheduled to be peer reviewed in summer 2023. The 

most recent peer review of the FCA OIG’s investigative program was performed by the 

Securities and Exchange Commission OIG for the one-year period ending September 

30, 2007. 

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

period. 

Outstanding Recommendations 

There are no outstanding recommendations from any peer review conducted by 

another OIG that have not been fully implemented. 

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

remain outstanding or that have not been fully implemented. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 18 
APPENDIX II: 

REPORTS ISSUED 

Table 4 lists all audit, inspection, and evaluation reports issued during the reporting 

period. For each report, Table 4 lists the dollar value of questioned costs (including the

dollar value of unsupported costs) and the dollar value of recommendations that funds

be put to better use. 

19 Farm Credit Administration | Office of Inspector General 

Table 4 

Report Title 

The Office of Secondary

Market Oversight’s

Examination Policies and 

Dollar Value of 

Questioned Costs 

Dollar Value of 

Recommendations 

that Funds be Put 

to Better Use Total Unsupported 

$0 $0 $0 

Procedures 

Survey of Farm Credit 

Administration Employees

on COVID-19 

$0 $0 $0 

Total $0 $0 $0 
APPENDIX III: 

REPORTS WITH 

QUESTIONED 

COSTS 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 20 

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

questioned costs, and the total dollar value of questioned costs associated with those 

reports. 

Table 5 

Requirement # Questioned 

Costs 

Unsupported

Costs 

(A) Reports for which no management

decision had been made by the 

commencement of the reporting period 

(B) Reports issued during the reporting 

period 

Subtotal (A+B) 

(C) Reports for which a management 

decision was made during the reporting 

period, including— 

(i) the dollar value of recommendations 

that were agreed to by management 

(ii) the dollar value of recommendations

that were not agreed to by 

management 

(D) Reports for which no management 

decision has been made by the end of

the reporting period 

0 

0 

0 

0 

0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 
APPENDIX IV: 

REPORTS WITH 

FUNDS 

FOR 

BETTER 

USE 

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

recommendations that funds be put to better use. 

Table 6 

Requirement # Unsupported

Costs 

(A) Reports for which no management decision had 

been made by the commencement of the reporting 

period 

(B) Reports issued during the reporting period 

Subtotal (A+B) 

(C) Reports for which a management decisi on was 

made during the reporting period, including— 

(i) the dollar value of recommendations that were 

agreed to by management 

(ii) the dollar value of recommendations that were not 

agreed to by management 

(D) Reports for which no management decision has 

been made by the end of the reporting period 

0 

0 

0 

0 

0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

21 Farm Credit Administration | Office of Inspector General 
 

 

 

 

 

 

 

S ONITANDEMOMCE

R N EP

O V: X DINEPP

A

Table 7 includes summary information regarding audit, inspection, and evaluation 

reports issued before April 1, 2021, for which there were outstanding unimplemented 

recommendations as of September 30, 2021, including the aggregate potential cost 

savings of those recommendations. There were no reports issued before the 

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

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

60 days. 

Table 7 

Report 

Outstanding

Unimplemented

Recommendations 

Aggregate

Potential Cost 

Savings 

The Farm Credit Administration’s 1 $0 

Compliance with the Federal 

Information Security Modernization Act 

for Fiscal Year 2020 

(October 30, 2020) 

Total: 1 $0 

Table 8 identifies recommendations made during previous reporting periods for which 

corrective action had not been completed as of September 30, 2021. An up-to-date list

of open OIG recommendations may be found at Oversight.gov/recommendations. 

Semiannual Report to Congress | April 1, 2021 – September 30, 2021 22 

Table 8 

Report Recommendation 

The Farm Credit 

Administration’s 

6 Not publicly released. 

Compliance with the 

Federal Information 

Security Modernization 

Act for Fiscal Year 2020 
INDEX OF 

REPORTING 

REQUIREMENTS 

The following is an index to IG Act reporting requirements. 

 

 

 

 

Section Description Page 

4(a)(2) Review of legislation and regulations 16 

5(a)(1) Significant problems, abuses, and deficiencies 7-9 

5(a)(2) Recommendations for corrective action 9-10 

5(a)(3) Recommendations described in previous semiannual 22 

reports for which corrective action has not been completed 

5(a)(4) Matters referred to prosecutive authorities 12 

5(a)(5) Reports of information or assistance unreasonably refused None 

or not provided 

5(a)(6) Audit, inspection, and evaluation reports issued 19 

5(a)(7) Summaries of significant reports 7-9 

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

5(a)(9) Management decisions on recommendations that funds be 21 

put to better use 

5(a)(10) Reports issued before the reporting period for which no 22 

management decision has been made, for which no 

comment was returned, and for which there are 

outstanding unimplemented recommendations 

5(a)(11) Significant revised management decisions None 

5(a)(12) Significant management decisions with which the IG None 

disagrees 

5(a)(13) Information described under section 804(b) of the Federal None 

Financial Management Improvement Act of 1996 

5(a)(14)-(15) Peer reviews conducted by another OIG 17-18 

5(a)(16) Peer reviews conducted by the FCA OIG 17-18 

5(a)(17) Statistical tables for investigations and referrals 12 

5(a)(18) Metrics for developing investigative statistics 12 

5(a)(19) Investigations involving a senior government employee None 

where allegations of misconduct were substantiated 

5(a)(20) Instances of whistleblower retaliation None 

5(a)(21) Attempts to interfere with OIG independence None 

5(a)(22)(A) Closed audits, inspections, and evaluations not disclosed to None 

the public 

5(a)(22)(B) Closed investigations involving a senior government None 

employee not disclosed to the public 

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

reportable under section 845 of the National Defense Authorization Act of 2008.5 

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

23 Farm Credit Administration | Office of Inspector General 

 

 

 

Credit Administration 

Office of Inspector General 

REPORT FRAUD, WASTE, ABUSE, & 

MISMANAGEMENT 

Fraud, waste, abuse, and mismanagement in government concerns

everyone: Office of Inspector General staff, Farm Credit Administration

employees, Congress, and the general public. We actively solicit 

allegations of any inefficient and wasteful practices, fraud, and 

mismanagement related to FCA programs and operations. You can

report allegations to us in several ways: 

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

(703) 883-4316 

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.