~ IG 

Fann Credit Administration 

Office of Inspector General 

Farm Credit Administration 

Office of Inspector General 

Semiannual Report to Congress 

October 1, 2020 – March 31, 2021 
A()IG 

Farm Credit Administration 

Office of Inspector General 

FARM CREDIT ADMINISTRATION 

OFFICE OF INSPECTOR GENERAL 

SEMIANNUAL REPORT TO CONGRESS 

OCTOBER 1, 2020 – MARCH 31, 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 October 1, 2020 through March 31, 2021. 

Though we have now marked over a year living with the pervasive 

impacts of the COVID-19 pandemic, I can report that my office has 

remained steadfast in providing independent and objective

oversight of FCA. 

This reporting period was a busy one for our audit, inspection, and evaluation function. 

We reviewed FCA’s process for separating employees and performed a timely

inspection of the Agency’s compliance with Executive Order 13950 on Combating Race 

and Sex Stereotyping. We also oversaw statutorily required audits of FCA’s financial 

statements and the Agency’s information security program. Finally, we initiated an audit 

of the Office of Secondary Market Oversight’s examination policies and procedures and 

an inspection of a survey on the Agency’s response to the COVID-19 pandemic. We

expect to report on the results of these ongoing reviews in the next reporting period. 

Over the last six months, our office continued to conduct outreach to FCA employees, 

whose cooperation is indispensable to our oversight. Building upon an initiative that 

began last July, we held three virtual town hall meetings with the aim of demystifying 

our office and eliciting discussion about what, why, and how we carry out our oversight

work. Given the encouraging response from Agency employees and management, we 

look forward to holding such meetings on a periodic basis going forward. We also 

added a new video to our website, providing employees and members of the public an 

introduction to the OIG’s mission and authorities. 

I am also pleased to note that the FCA Board issued a statement to Agency personnel 

encouraging cooperation with the OIG. This statement, drafted in consultation with our 

office, reflects a welcome view on our office’s oversight. 

Our office continued to contribute to the inspector general (IG) community. I served 

throughout the reporting period as Chair of the Inspection and Evaluation (I&E) 

Committee of the Council of the Inspectors General on Integrity and Efficiency (CIGIE), 

and members of my staff played a substantial role in the development of revised quality 

standards that will govern I&E work across the IG community for years to come. I was 

also asked to serve on the CIGIE panel that makes recommendations on potential IG 

candidates to the appropriate appointing authorities. In November, our investigator 

gave a talk, “A Career is Like a Jigsaw Puzzle,” to an audience of hundreds as part of the 

7th Annual CIGIE Leadership Forum. I am also proud to report that in October, our 

Assistant Inspector General for Audits, Inspections, and Evaluations received a CIGIE 

award as part of a working group responsible for implementation of the first-ever peer 

review process for I&E work. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 i 
 

We look forward to the synergy created when we are once again able to be in the office 

together in-person. As we develop our new normal, though, we look forward to 

harnessing the advantages and flexibilities of the virtual work environment. And while 

the past year has been a challenging one, we stand ready to work with the new 

administration and new congressional leaders as we strive to ensure that our 

government continues to be a beacon of hope and freedom for the world. 

Wendy R. Laguarda

Inspector General 

ii Farm Credit Administration | Office of Inspector General 
 

ACRONYMS AND 

ABBREVIATIONS 

AIGAIE Assistant Inspector General for Audits, Inspections, and 

Evaluations 

CIGIE Council of the Inspectors General on Integrity and Efficiency 

E.O. Executive Order 

Farmer Mac Federal Agricultural Mortgage Corporation 

FCA (or Agency) Farm Credit Administration 

FY Fiscal Year 

GAO U.S. Government Accountability Office 

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

I&E Inspection and Evaluation 

IG Inspector General 

IG Act Inspector General Act of 1978, as amended 

IT Information Technology 

OIG Office of Inspector General 

OMB U.S. Office of Management and Budget 

OSMO Office of Secondary Market Oversight 

Pub. L. Public Law 

System Farm Credit System 

U.S. United States 

U.S.C. United States Code 

Williams Adley Williams Adley & Company-DC LLP 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 iii 
TABLE OF 

CONTENTS 

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

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

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

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

Audits, Inspections, and Evaluations .................................................................................................. 4 

Investigations ............................................................................................................................................ 10 

Other Reports and Reviews ................................................................................................................. 12 

Outreach, Collaboration, and Other Initiatives............................................................................. 13 

Appendix I: Peer Reviews ...................................................................................................................... 15 

Appendix II: Reports Issued ................................................................................................................. 17 

Appendix III: Reports with Questioned Costs ............................................................................... 18 

Appendix IV: Reports with Funds For Better Use......................................................................... 19 

Appendix V: Open Recommendations ............................................................................................ 20 

Index of Reporting Requirements ..................................................................................................... 21 

iv Farm Credit Administration | Office of Inspector General 
BACKGROUND 

The Farm Credit System 

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

borrower-owned cooperative financial institutions and service organizations. A 

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

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

source of credit and related financial services. 

As of the end of the reporting period, the System consisted of three farm credit banks, 

one agricultural credit bank, one federal land credit association and 67 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,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 Chairman of the Board—who 

is designated by the President and serves in that role until the end of his or her 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. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 1 
 

 

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. 

2 Farm Credit Administration | Office of Inspector General 
STRATEGIC 

PLAN 

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

to 2024. The plan details the vision, mission, values, goals, and objectives of the OIG in 

carrying out its responsibilities under the IG Act and establishes certain measures 

against which the OIG will benchmark its performance. 

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 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 3 
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, and statutory requirements. For more 

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

evaluation plan for FYs 2021 and 2022. 

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 four reports and made fourteen recommendations for corrective action 

during the reporting period. The reports are summarized below. 

Farm Credit Administration’s Employee Separation Process

A-20-01 

Maintaining a well-trained, sustainable workforce is vital to fulfillment of FCA’s mission, 

and as such, the OIG has consistently recognized this as a significant management 

challenge facing the Agency. Each year, the Agency loses some of its employees for a 

variety of reasons, including retirements, transfers, and resignations. When an 

employee elects to leave the Agency, the separation process is initiated. This process

helps ensure that equipment is returned, accesses are terminated, personnel are 

counseled regarding post-employment restrictions, and feedback is collected. The 

employee separation process also represents a unique opportunity to capture 

employees’ thoughts and experiences regarding the Agency and, in so doing, identify 

ways to improve the work environment. 

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

process for separating employees. To address this objective, the OIG analyzed the 

separation processes currently in place and reviewed the number of separations by 

year, type of separation, office, series, and location in order to understand the impact 

of employee separations on the Agency. 

While the Agency had enhanced its separation process in certain ways, the OIG 

identified opportunities to improve the overall effectiveness and efficiency of the 

process. For example, FCA uses an electronic Personnel Action Report to notify offices 

and officials with a role in the separation process of upcoming actions, but the OIG 

4 Farm Credit Administration | Office of Inspector General 
identified errors in the electronic listing. FCA also lacked documentation describing its 

voluntary exit survey process and how the Agency will use the data collected through 

that process. The Agency also gives separating employees the option to meet with the 

human resources supervisor for an interview, but this process similarly lacked 

documentation. Lastly, the OIG identified an inconsistent approach to properly 

separating employees with missing or incomplete checkout record forms. 

The OIG identified several factors that contributed to inconsistencies and exceptions in 

the separation process, including outdated policies and procedures as well as personnel 

turnover and restructuring in the Office of Agency Services, which manages and delivers 

human capital and administrative services for FCA. The OIG also noted that the Agency 

lacked certain controls and a plan for analyzing and reporting on the data collected 

through the separation process. 

The OIG made six recommendations for corrective action. FCA agreed with one of the 

recommendations. Although the Agency only partially agreed with the remaining five 

recommendations, the OIG determined that the management actions planned or 

completed in response to the audit addressed the weaknesses identified in the report. 

The OIG issued the audit report on February 9, 2021. 

Farm Credit Administration’s Compliance with Executive Order 13950

on Combating Race and Sex Stereotyping

I-21-01 

On September 22, 2020, President Trump issued Executive Order (E.O.) 13950 on

Combating Race and Sex Stereotyping. E.O. 13950 stated that “it shall be the policy of

the United States not to promote race or sex stereotyping or scapegoating in the 

Federal workforce” and imposed various requirements upon federal agencies. These 

included mandates for contract and grant administration, prohibitions against training

programs involving “divisive concepts” defined in the order, and reporting regarding 

diversity and inclusion-related training programs. 

E.O. 13950 additionally required that agency heads request that their IG review and

assess agency compliance with the order. The FCA Board Chairman made such a 

request to the OIG on October 5, 2020. This inspection was initiated in response to this 

request, with an objective of reviewing and assessing Agency compliance with the 

requirements of E.O. 13950. The scope was limited to the Agency’s progress from 

September 2020 through December 2020. 

Based on the limited review performed, the OIG determined that FCA complied with all 

relevant requirements of E.O. 13950. The Agency incorporated mandatory contract

provisions into contracts awarded after November 21, 2020. It took steps to ensure 

employees would not receive training on matters prohibited by the order. Further, the 

FCA Board Chairman issued a memorandum to senior staff requiring incorporation of

E.O. 13950’s requirements into Agency operations, selected an official to serve as the 

senior political appointee responsible for ensuring compliance with E.O. 13950, and

requested that the OIG assess the Agency’s compliance. FCA also reported its FY 2020 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 5 
spending on diversity and inclusion training to the U.S. Office of Management and 

Budget (OMB) as required. 

The OIG issued the inspection report on December 18, 2020. On January 20, 2021, 

President Biden revoked E.O. 13950. 

Audit of the Farm Credit Administration’s Financial Statements 

Fiscal Year 2020 

A-20-FS 

Under the Accountability of Tax Dollars Act of 2002,3 FCA is required each year to 

submit audited financial statements to Congress and OMB. For FY 2020, the OIG 

engaged independent public accounting firm Harper, Rains, Knight & Company, P.A. 

(HRK), to audit FCA’s financial statements. The OIG monitored the work of HRK for 

compliance with the Government Auditing Standards. 

HRK concluded the audit in November 2020, issuing an unmodified opinion signifying 

that the financial statements present fairly, in all material respects, FCA’s financial 

position as of September 30, 2020 and 2019, and its net cost of operations, changes in 

net position, and budgetary resources for the fiscal years then ended, in accordance 

with generally accepted accounting principles. 

HRK considered FCA’s internal control over financial reporting as a basis for designing 

audit procedures for the purpose of expressing an opinion on the financial statements. 

The auditors did not express an opinion on the effectiveness of those internal controls; 

however, they did not identify any deficiencies considered to be a material weakness. 

Additionally, HRK performed tests of FCA’s compliance with selected provisions of laws 

and regulations that would have a direct and material effect on the financial statements. 

While the auditors did not express an opinion on compliance with those provisions, 

they did not identify any reportable instances of noncompliance or other matters 

required to be reported under the Government Auditing Standards or relevant OMB 

guidance. 

The OIG’s monitoring and review of HRK disclosed no instances where HRK did not 

comply, in all material respects, with the Government Auditing Standards. 

The OIG issued the audit report on November 12, 2020, and HRK presented the report

at the January 2021 meeting of the FCA Board. 

The Farm Credit Administration’s Compliance with the Federal Information

Security Modernization Act for Fiscal Year 2020

A-20-02 

Information technology (IT) facilitates and impacts all aspects of FCA operations. As 

such, securing Agency IT systems against cybersecurity threats and efficiently 

addressing IT requirements are vital to the fulfillment of FCA’s mission. Pursuant to the 

Federal Information Security Modernization Act of 2014 (FISMA),

4 the OIG annually 

3 Pub. L. 107-289 (Nov. 7, 2002). 

4 44 U.S.C. § 3555(b)(1). 

6 Farm Credit Administration | Office of Inspector General 
assesses FCA’s progress in meeting this ever-evolving challenge. FISMA requires OIGs 

to independently evaluate their respective agency’s information security program and 

practices. The OIG contracted with independent public accounting firm Williams Adley 

& Company-DC LLP (Williams Adley) to perform this review for FY 2020. The OIG

monitored the work of Williams Adley for compliance with the Government Auditing 

Standards. 

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

Security, and CIGIE, Williams Adley assessed FCA’s performance with respect to 67 

metrics across eight domains: risk management, configuration management, identity 

and access management, data protection and privacy, security training, information 

security continuous monitoring, incident response, and contingency planning. For each 

domain, FCA’s effectiveness was ranked according to a maturity model ranging from 

“ad hoc” (at level 1) to “optimized” (at level 5). A “managed and measurable” (level 4) 

information security program is considered to be operating at an effective level of 

security. 

Based on these metrics, Williams Adley concluded that FCA had implemented an 

effective security program in FY 2020. The Agency continued to improve its information 

security program and made progress in implementing recommendations made as part 

of previous FISMA evaluations. Williams Adley determined that the Agency was 

“managed and measurable” (level 4) for two domains and “consistently implemented” 

(level 3) for four domains. With respect to the data protection and privacy and 

contingency planning domains, Williams Adley ranked the Agency as “defined” (level 2) 

and “ad-hoc” (level 1), respectively. 

Williams Adley made eight recommendations for corrective action. FCA agreed with all 

of the recommendations. 

The OIG’s monitoring and review of Williams Adley disclosed no instances where 

Williams Adley did not comply, in all material respects, with the Government Auditing 

Standards. 

The OIG issued the audit report on October 30, 2020, and Williams Adley presented the 

report at the January 2021 meeting of the FCA Board. 

Recommendations Made During the Reporting Period 

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

period. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 7 
Table 1 

Report Recommendation 

Farm Credit 

Administration’s Employee 

Separation Process 

1 The Office of Inspector General recommends the 

Office of Agency Services update Policies and 

Procedures Manual 834 to reflect the Personnel 

Action Report process, update responsibilities and 

references, and document the exit interview process. 

2 The Office of Inspector General recommends the 

Office of Agency Services update the Office of Agency 

Services Directive 007 to reflect current processes in 

the separation process. 

3 The Office of Inspector General recommends the 

Office of Agency Services implement additional 

controls over the Personnel Action Report entries and

the employee checkout forms. This may include 

annual reviews, inclusion in the internal control review 

cycle, supervisory review, or other controls deemed 

necessary by the Office of Agency Services. 

4 The Office of Inspector General recommends the 

Office of Agency Services determine records retention 

practices for information kept on exiting personnel 

including, but not limited to, checkout forms, exit 

surveys, and interview documentation, and update 

record retention policies and procedures as needed. 

5 The Office of Inspector General recommends the 

Office of Agency Services evaluate the exit survey and 

interview process to assess the efficacy of the 

questions and the feedback. 

6 The Office of Inspector General recommends the 

Office of Agency Services implement a plan on how

the Agency will use the exit survey and interview data 

to include analyzing and comparing trends in 

employee separations and reporting or briefing the 

information to key Agency officials at a designated 

interval. 

Farm Credit 

Administration’s 

1 Not publicly released. 

2 Not publicly released. 

Compliance with the 

Federal Information 

Security Modernization Act

for Fiscal Year 2020 

3 Not publicly released. 

4 Not publicly released. 

5 Not publicly released. 

6 Not publicly released. 

7 Not publicly released. 

8 Not publicly released. 

8 Farm Credit Administration | Office of Inspector General 
 

 

 

In Progress 

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

reporting period. 

The Office of Secondary Market Oversight’s

Examination Policies and Procedures 

Unique among System institutions, Farmer Mac was established with a mission to 

provide a secondary market for agricultural lending. Within FCA, the Office of 

Secondary Market Oversight (OSMO) provides for the examination, regulation, and 

supervision of Farmer Mac. The OIG has recognized this responsibility as a significant 

management challenge facing the Agency. Among its other duties, OSMO is required 

to examine Farmer Mac no less than once each year. The objective of this audit is to 

determine whether OSMO examination policies and procedures are documented and 

implemented. 

Survey of FCA Employees on COVID-19 

FCA has implemented several measures to protect Agency employees since the onset

of the COVID-19 pandemic, including moving to a mandatory telework status in March 

2020. The objective of this inspection is to conduct a survey of FCA employees on the 

safety measures and other actions implemented by the Agency in response to COVID19. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 9 
10 Farm Credit Administration | Office of Inspector General

INVESTIGATIONS

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

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

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

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

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

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

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

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

identified through OIG audits, inspections, and evaluations.

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

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

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

Standards for Investigations. 

Table 2 summarizes major investigative activity during the reporting period.

Table 2 

Metric Number

Investigative reports issued5 0

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

prosecution

0

Persons referred to state and local prosecuting authorities for criminal 

prosecution

0

Indictments and criminal informations that resulted from any prior 

referral to prosecuting authorities

0

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.6

 Table 3 shows the OIG’s

response to complaints received during the reporting period. 

Action Taken Number

Investigation opened 0

Closed after review with no further specific investigative action 14

Referred to FCA program manager 4

Referred to other federal, state, or local agency or authority 1

Under review at the end of the reporting period 2

Total 21

Table 3 

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

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

make complaints to telephone and email.
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. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 11 
 

OTHER 

REPORTS AND 

REVIEWS 

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

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

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

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

such reviews that were completed during the reporting period. 

Management Challenges 

In accordance with the Reports Consolidation Act of 2002,7 the OIG annually prepares 

a statement summarizing what the IG considers to be the most serious management

and performance challenges facing FCA. The statement also assesses the Agency’s 

progress in meeting those challenges and highlights relevant OIG oversight work. 

For FY 2020, the OIG highlighted five challenges facing the Agency, all of which were 

previously identified in the OIG’s FY 2019 report: 

Examination and Supervision Program: Identifying and addressing risks in the 

System through effective examination and supervision to ensure it remains safe 

and sound. 

Information Technology: Leveraging investments in information technology 

while maintaining a secure environment and mobile workforce. 

Data Quality and Analysis: Obtaining consistent and quality data vital to FCA's 

mission. 

Human Capital: Maintaining a well-trained, sustainable workforce while facing 

challenges in retirement eligibilities, workforce retention, and diversity. 

Secondary Market Oversight: Providing effective and impartial oversight of 

Farmer Mac through FCA’s OSMO. 

Within the context of each of these challenges, the report discusses the relevance and 

impact of the COVID-19 pandemic. 

The report was issued to the FCA Board on October 9, 2020. FCA management’s 

response can be found in the Agency’s Performance and Accountability Report for FY 

2020. 

FY 2020 Charge Card Letter 

In accordance with the Government Charge Card Abuse Prevention Act of 20128 and 

implementing OMB guidance, the OIG conducts periodic risk assessments of FCA

charge card programs to analyze the risk of illegal, improper, or erroneous purchases. 

The OIG also reports to OMB on the Agency’s progress in implementing charge cardrelated recommendations. 

For FY 2020, the OIG issued a letter to OMB stating that there were no charge cardrelated recommendations implemented or closed for FY 2020. 

7 31 U.S.C. § 3516(d). 

8 41 U.S.C. § 1909(d). 

12 Farm Credit Administration | Office of Inspector General 
 

OUTREACH, 

COLLABORATION, AND 

OTHER INITIATIVES 

FCA Employees 

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

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

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

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

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

orientation trainings for new FCA employees and distributes posters to promote 

awareness of the OIG hotline. In November, the OIG added a ---video to its website 

introducing employees and the public to the office and its mission. 

In March, the OIG held three virtual town hall meetings with Agency personnel. 

Designed to demystify the OIG, these meetings afforded OIG staff an opportunity to 

reintroduce themselves to Agency personnel and provide insight into the OIG’s audit, 

inspection, evaluation, and investigation processes. This outreach initiative is a 

continuation of one that began in July 2020 for employees of the FCA Office of 

Examination. Based on the encouraging response from Agency personnel and 

management, the OIG plans to hold similar meetings at regular intervals in the future. 

This reporting period, the FCA Board distributed a statement encouraging agency 

personnel to report fraud, waste and abuse to the OIG and to cooperate with OIG 

requests for information. This statement, drafted in consultation with the OIG, extolled 

the benefits of OIG oversight to the Agency’s mission. 

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. 

IG 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 I&E peer review process. Under the purview of this committee, the AIGAIE 

led the I&E Roundtable and a working group whose efforts culminated in CIGIE’s 

adoption of revised I&E quality standards in December 2020. This reporting period, OIG

personnel also prepared a guide—jointly distributed by the CIGIE I&E and Audit 

Committees—for reviews conducted pursuant to E.O. 13950 on Combating Race and 

Sex Stereotyping. 

The IG also served on the CIGIE Legislation Committee, which fosters relationships with 

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

OIGs apprised of pertinent legislative developments. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 13 
 

 

 

The IG began serving this reporting period as a member of CIGIE’s IG candidate panel,

which reviews potential IG candidates and makes recommendations to the appropriate 

appointing authorities—the President or agency head. With over a dozen IG vacancies 

in the Executive Branch at the end of 2020, this panel has been busy reviewing potential 

IG candidates since the beginning of the calendar year. 

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. 

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. 

The OIG provided comments on proposed legislation through the CIGIE Legislation 

Committee. 

Internal Operations 

The OIG is in constant pursuit of ways to improve its own operations. This reporting 

period, the OIG undertook to improve office awareness and consciousness of diversity, 

equity, and inclusion 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. With the success of these sessions, the OIG plans to engage in similar 

practices in the future. 

14 Farm Credit Administration | Office of Inspector General 
APPENDIX I: 

PEER 

REVIEWS 

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

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

provided below. 

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

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

websites of the reviewed OIGs. 

Audit 

The 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. 

Semiannual Report to Congress | October 1, 2020 – March 31, 2021 15 
 

 

 

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 beginning in 2022. 

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. 

16 Farm Credit Administration | Office of Inspector General 
Semiannual Report to Congress | October 1, 2020 – March 31, 2021 17

APPENDIX II:

REPORTS ISSUED

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

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

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

be put to better use. 

Table 4 

Report Title

Dollar Value of

Questioned Costs 

Total Unsupported

Dollar Value of 

Recommendations 

that Funds be Put 

to Better Use

Farm Credit 

Administration’s Employee 

Separation Process

Farm Credit 

Administration’s 

Compliance with Executive 

Order 13950 on 

Combating Race and Sex 

Stereotyping

Audit of the Farm Credit 

Administration’s Financial 

Statements Fiscal Year 

2020

The Farm Credit 

Administration’s 

Compliance with the 

Federal Information 

Security Modernization Act 

for Fiscal Year 2020

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

$0

Total $0 $0 $0
18 Farm Credit Administration | Office of Inspector General

APPENDIX III:

REPORTS WITH 

QUESTIONED 

COSTS

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

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

reports.

Table 5 

Requirement # Questioned 

Costs

Unsupported 

Costs

(A) Reports for which no management 

decision had been made by the 

commencement of the reporting period

(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
Semiannual Report to Congress | October 1, 2020 – March 31, 2021 19

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 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
20 Farm Credit Administration | Office of Inspector General

APPENDIX V:

OPEN 

RECOMMENDATIONS

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

reports issued before October 1, 2020, for which there are outstanding unimplemented 

recommendations, 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

OIG 2018 Evaluation of the Farm Credit 

Administration’s Compliance with the 

Federal Information Security 

Modernization Act

(October 31, 2018)

1 $0

Total: 1 $0

Table 8 identifies recommendations made during previous reporting periods for which 

corrective action had not been completed as of March 31, 2021. An up-to-date list of 

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

Table 8 

Report Recommendation

OIG 2018 Evaluation of 

the Farm Credit 

Administration’s 

Compliance with the 

Federal Information 

Security Modernization 

Act

5 The Office of Information Technology needs to 

develop policies and procedures related to 

preventing data exfiltration.
Semiannual Report to Congress | October 1, 2020 – March 31, 2021 21

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 14

5(a)(1) Significant problems, abuses, and deficiencies 4-7

5(a)(2) Recommendations for corrective action 7-8

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

reports for which corrective action has not been completed

20

5(a)(4) Matters referred to prosecutive authorities 10

5(a)(5) Reports of information or assistance unreasonably refused

or not provided

None

5(a)(6) Audit, inspection, and evaluation reports issued 17

5(a)(7) Summaries of significant reports 4-7

5(a)(8) Management decisions with respect to questioned costs 18

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

put to better use

19

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

management decision has been made, for which no

comment was returned, and for which there are 

outstanding unimplemented recommendations

20

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

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

disagrees

None

5(a)(13) Information described under section 804(b) of the Federal

Financial Management Improvement Act of 1996

None

5(a)(14)-(15) Peer reviews conducted by another OIG 15-16

5(a)(16) Peer reviews conducted by the FCA OIG 15-16

5(a)(17) Statistical tables for investigations and referrals 10

5(a)(18) Metrics for developing investigative statistics 10

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

where allegations of misconduct were substantiated

None

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

the public

None

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

employee not disclosed to the public

None

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

reportable under section 845 of the National Defense Authorization Act of 2008.9

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

Credit Administration 

Office of Inspector General 

REPORT FRAUD, WASTE, ABUSE, & 

MISMANAGEMENT: 

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

(703) 883-4316 

Fax: (703) 883-4059 

Email: fca-ig-hotline@rcn.com 

Mail: 1501 Farm Credit Drive 

McLean, VA 22102-5090 

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

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