1

Summary of 2004 Performance Results by Program

The FDIC successfully achieved 26 of the 31 annual performance targets 

established in its 2004 Annual Performance Plan. Three performance targets were

not applicable and two were not met. The FDIC did not hold a Future of Banking

Conference in 2004, as originally planned. Instead, it elected to disseminate the

results of the study and solicit feedback from interested parties by publishing

papers from the study on the FDIC Web site and discussion of the study results

in FDIC publications and speeches by senior FDIC officials. Originally scheduled

for implementation in October 2004, rollout of the Call Data Repository was

postponed to address industry feedback and allow more time for system testing

and enrollment of financial institutions.

Key accomplishments by program are highlighted below. There were no

instances in which 2004 performance had a material adverse effect on 

successful achievement of the FDIC’s mission or its strategic goals and objectives

with respect to its major program responsibilities. In addition, consideration 

of 2004 performance results was an integral part of the development of the

FDIC’s 2005 Annual Performance Goals. 

The Office of Inspector General (OIG) has shared its view of the most significant

challenges the Corporation is confronting and has acknowledged actions 

underway to address these issues. (See Appendix C for a list of these challenges.)

Management is committed to addressing each of the issues identified by the

OIG.

III. Performance

Results

Summary
29

Program Area Performance Results

Insurance ● Resolved four failed insured institutions, providing depositors with access to insured deposits 

in each case. For three of the four failures, depositors had uninterrupted and continuous access 

to insured deposits as the deposits were assumed by an acquiring entity. One of the four failures 

was a payout.

● Completed implementation of enhancements to the reserving process and methodology in 

accordance with recommendations from a comprehensive study. 

● Congress did not enact deposit insurance reform legislation. The FDIC will continue to press 

for reform. 

● Completed risk assessments for all large insured depository institutions and followed up on all 

identified concerns referred for examination or other supervisory action.

● Improved the accuracy and efficiency of off-site risk identification models.

● Completed the development of a CD-ROM and Internet-based resource for bankers on the 

deposit insurance rules.

● Published economic and banking information and analysis:

● Four FDIC Outlook publications.

● Ten FYI electronic bulletins.

● Four editions of the FDIC Quarterly Banking Profile (QBP).

● Four editions of the FDIC State Profiles.

● Five articles authored or co-authored by FDIC staff accepted for publication 

in professional journals. 

Supervision and ● Conducted 2,515 safety and soundness examinations. This included all statutorily required safety 

Consumer Protection and soundness examinations, except for a small number deferred due to pending mergers.

● Conducted 2,136 compliance and Community Reinvestment Act examinations in accordance 

with FDIC policy.

● Participated in 125 Money Smart events and technical assistance activities related to the 

Community Reinvestment Act, fair lending and community development, and added 200 

Money Smart Alliance members and distributed 20,000 copies of the Money Smart curriculum.

Receivership ● Contacted all qualified potential bidders in three of the four institution failures in 2004. One failed

Management institution was not offered for sale as a result of fraud allegations and little advance notice of 

the closing.

l ● Marketed 100 percent of marketable assets of five failed financial institutions within 90 days 

of failure (one of the institutions failed in late 2003).

● Terminated three receiverships, meeting the target to terminate 75 percent within three years 

of failure date.
2004 Budget and Expenditures by Program

The FDIC budget for 2004 totaled $1.210 billion. Excluding $147 million for

Corporate General and Administrative expenditures, budget amounts were 

allocated to corporate programs and related goals as follows: $221 million, 

or 18 percent, to the Insurance program; $567 million, or 47 percent, to the

Supervision and Consumer Protection program; and $275 million, or 23 percent,

to the Receivership Management program. 

Actual expenditures for the year totaled $1.112 billion. Excluding $131 million 

for Corporate General and Administrative expenditures, actual expenditures

were allocated to programs as follows: $143 million, or 13 percent, to the

Insurance program; $631 million, or 57 percent, to the Supervision and Consumer

Protection program; and $207 million, or 19 percent, to the Receivership

Management program. 

30

Expenditures

Budget

$ 700

$ 600

500

400

300

200

100

0

Insurance Supervision and Receivership General 

Program Consumer Protection Management and

Program Program Administrative 

2004 Expenditures and Budget (Support Allocated) 

Dollars in Millions
31

Performance Results by Program and Strategic Goal

Insurance Program Results

Strategic Goal: Insured depositors are protected from loss without recourse to taxpayer funding.

Annual Performance Goal Indicator Target Results

1. Respond promptly to all financial Number of business days after If the failure occurs on Achieved.

institution closings and emerging institution failure by which a Friday the target is one See pg. 19.

issues. depositors will have access business day.

to insured funds either through 

transfer of deposits to successor If the failure occurs on any Not 

insured depository institution other day of the week, the Applicable.

or depositor payout. target is two business days. All failures

occurred on

a Friday.

2. Identify and address risks to the Assess risks posed by large Assess risks in 100 percent Achieved.

insurance funds. insured depository institutions. of large insured depository See pg. 11.

institutions and adopt 

appropriate strategies.

Identify and follow up on concerns Identify and follow up on Achieved.

referred for examination or other 100 percent of referrals. See pg. 12.

action (i.e., contact the insured 

institution or primary supervisor).

Disseminate data and analyses Analyses are included in Achieved.

on current issues and risks regular publications or as See pg. 11.

affecting the banking industry ad hoc reports on a timely 

to bankers, supervisors, basis.

stakeholders, and the public.

Conduct industry outreach Achieved.

activities aimed at the banking See pg. 11.

community and industry trade

groups to discuss current 

trends and concerns and 

to inform bankers about 

available FDIC resources.

3. Maintain sufficient and reliable Maintain quality and timeliness Implement a modernized Not

information on insured depository of bank data. Call Reporting process by Achieved.

institutions. December 31, 2004. See pg. 11. 
Insurance Program Results (continued)

Strategic Goal: Insured depositors are protected from loss without recourse to taxpayer funding.

Annual Performance Goal Indicator Target Results

4. Maintain and improve the deposit Pursuit of changes to the Provide information and Achieved.

insurance system. deposit insurance system is analysis to Congressional See pgs.

in accordance with proposals committees in support of 8-9.

submitted to the Congress. deposit insurance reform

legislation.

Develop and obtain the Achieved.

necessary support for a See pgs.

proposed assessment credit 8-9.

and rebate system and a

new deposit insurance 

pricing system.

When deposit insurance Not 

reform is enacted, implement Applicable.

legislation in accordance Legislation

with statutorily prescribed not enacted

time frames. in 2004.

Make appropriate changes to Review discrepancies Achieved.

the current methodology for between projected failed See pgs.

projecting losses in failing assets and actual failed assets 8-9.

financial institutions and by applying sophisticated

establishing related loss analytical techniques to

reserves for the deposit examine the effectiveness

insurance funds. of the loss projection model

and adjust the methodology

for projecting losses

accordingly.

Implement enhancements Achieved.

to the reserving process and See pgs.

methodology in accordance 8-9.

with recommendations from 

a comprehensive 2003 review.

Maintain fund adequacy. Set assessment rates to Achieved.

maintain the insurance funds See pgs.

at the designated reserve 8-9.

ratio, or return them to the 

designated reserve ratio if 

they fall below it, as required 

by statute. 

32
33

Insurance Program Results (continued)

Strategic Goal: Insured depositors are protected from loss without recourse to taxpayer funding.

Annual Performance Goal Indicator Target Results

If deposit insurance reform Not

legislation becomes law in Applicable.

2004, promulgate rules and Legislation

regulations establishing criteria not enacted

for replenishing the deposit in 2004.

insurance fund when it falls

below the low end of the range.

Develop a working prototype Achieved.

of a new, integrated fund See pgs.

model for financial risk 8-9.

management.

Conduct a conference on the Host conference, present Not

“Future of Banking.” findings from the study and Achieved.

obtain feedback from scholars See pg.28.

and industry representatives 

and other interested parties. 

Maintain quality and visibility Implement an FDIC Center Achieved.

of the Corporation’s banking for Financial Research with See pg.10.

research activities. enhanced ties to the academic

community.

5. Provide educational information Utility of educational tools Develop a CD-ROM and Achieved.

to insured depository institutions developed for bankers and Internet-based resource for See pg.18.

and their customers to help them consumers. bankers on the deposit

understand the rules for determining insurance rules. 

the amount of insurance coverage 

on deposit accounts.
34

Supervision and Consumer Protection Program Results 

Strategic Goal: FDIC-supervised institutions are safe and sound.

Annual Performance Goal Indicator Target Results

1. Conduct on-site risk management Percentage of required One hundred percent of Achieved.

examinations to assess an FDIC- examinations in accordance required examinations are See pg.12.

supervised insured depository with statutory requirements conducted on time.

institution’s overall financial condition, and FDIC policy.

management practices and polices, 

and compliance with applicable laws

and regulations.

2. Take prompt supervisory actions to Follow-up examination of Follow-up examination is Achieved.

address problems found during the problem banks. conducted within 12 months See pg.12.

FDIC examination of FDIC-supervised of completion of the prior

institutions identified as problem examination.

insured depository institutions. 

Monitor FDIC-supervised insured 

depository institutions’ compliance 

with formal and informal enforcement 

actions.

Strategic Goal: Consumers’ rights are protected and FDIC-supervised institutions invest in their communities.

1. Provide effective outreach and Additions to the Money Smart Add an additional 200 Money Achieved.

technical assistance on topics related Alliance and the number of Smart Alliance Members. See pg.15.

to CRA, fair lending, and community Money Smart curriculum

development. provided.

Provide an additional 20,000 Achieved.

copies of Money Smart See pg.15.

curriculum.

Reach an additional 200,000 Achieved.

individuals. See pg.15.

Outreach activities and Conduct or participate in125 Achieved.

technical assistance. technical assistance efforts See pg.15.

(examination support) or 

banker/community outreach 

activities related to CRA, 

fair lending, or community 

development.

2. Effectively meet the statutory mandate Timely responses to written Ninety percent of written Achieved.

to investigate and respond to complaints. complaints are responded See pg.17.

consumer complaints about FDIC- to within time frames

supervised financial institutions. established by policy.
35

Supervision and Consumer Protection Program Results (continued)

Strategic Goal: Consumers’ rights are protected and FDIC-supervised institutions invest in their communities.

Annual Performance Goal Indicator Target Results

3. Conduct comprehensive and Conduct required examinations One hundred percent of Achieved.

compliance-only examinations in accordance with FDIC policy. required examinations are See pg.12.

in accordance with FDIC conducted within time frames 

examination frequency policy. established by FDIC policy.

4. Take prompt supervisory actions and Timely follow-up examinations Follow-up examination or Achieved.

monitor institutions rated “4” or “5” and related activity. related activity is conducted See pg.12.

for compliance to address problems within 12 months from the

identified during compliance date of a formal enforcement

examinations. action to confirm that the 

institution is in compliance

with the enforcement action.

Receivership Management Program Results 

Strategic Goal: Recovery to creditors of receivership is achieved.

1. Market failing institutions to all known List of qualified and interested Contact all known qualified Achieved.

qualified and interested potential bidders. and interested bidders. See pg.19.

bidders.

2. Value, manage, and market assets of Percentage of failed institution’s Eighty-five percent of book Achieved.

failed institutions and their subsidiaries assets marketed. value of a failed institution’s See pg.19.

in a timely manner to maximize net marketable assets are

return. marketed within 90 days 

of failure.

3. Manage the receivership estate and Timely termination of new Terminate 75 percent of Achieved. 

its subsidiaries toward an orderly receiverships. receiverships managed through See pg.20.

termination. the Receivership Oversight 

Program within three years 

of the failure date.

4. Conduct investigations into all Percentage of investigated claim For 80 percent of all claim Achieved.

potential professional liability claim areas for which a decision has areas, a decision is made See pg.19.

areas in all failed insured depository been made to close or pursue to close or pursue the claim

institutions and decide as promptly the claim. within 18 months after the

as possible to close or pursue each failure date.

claim, considering the size and 

complexity of the institution.
Depositor Payouts in Instance of Failure

Annual Goal 2001 Results 2002 Results 2003 Results 2004 Results

The FDIC responds promptly Timely payments made Timely payments made Timely payments made Timely payments made

to financial institution closings to all depositors of the to all depositors of the to all depositors of the to all depositors of the

and emerging issues. four insured depository 11 insured depository three insured depository four insured depository

institutions that failed institutions that failed institutions that failed institutions that failed

in 2001. in 2002. in 2003. in 2004.

Legislation on deposit Legislation on deposit

insurance reform was insurance reform was

introduced in the House passed in the House 

and the Senate. and was pending in the 

Senate when Congress

recessed for the year. 

Risk Classifications

Maintain and improve the Bank Insurance Fund (BIF) BIF and SAIF reserve BIF and SAIF reserve The FDIC completed

deposit insurance system. and Savings Association ratios maintained at ratios maintained at implementation of

Insurance Fund (SAIF) or above the statutory or above the statutory enhancements to the

reserve ratios maintained. ratio of 1.25 percent. ratio of 1.25 percent. reserving process and

FDIC published its final Chairman testified before Chairman testified before methodology in

recommendations for the Senate Committee the Senate Committee March 2004. During 

deposit insurance reform. in support of deposit in support of deposit 2004, assessment rates

insurance reform. insurance reform. were maintained at or

above the designated

reserve ratio as 

required by statute.

Identify and address risks Developed several Significant progress Significant progress was Significant progress was

to the insurance funds. approaches to credit risk made in improving the made in improving the made in improving the

that will be incorporated accuracy and efficiency accuracy and efficiency accuracy and efficiency

into Virtual Supervisory of off-site risk of off-site risk of off-site risk 

Information On the Net identification models. identification models. identification models.

(ViSION) system. Risk Risk assessments of Risk assessments of Risk assessments of 

assessments of all large all large insured all large insured all large insured

insured depository depository institutions depository institutions depository institutions

institutions (LIDIs) (LIDIs) were completed (LIDIs) were completed (LIDIs) were completed

were completed in compliance with in compliance with in compliance with 

in compliance with program requirements. program requirements. program requirements. 

program requirements.

Maintain sufficient and Annual goal was not Annual goal was not Annual goal was not The Central Data

reliable information on established in 2001. established in 2002. established in 2003. Repository (CDR) system

insured depository is being developed. 

institutions. Phase I of the CDR is 

expected to be delivered 

by the end of 2005.

36

Multi-Year Performance Trend
37

Risk Classifications (continued)

Annual Goal 2001 Results 2002 Results 2003 Results 2004 Results

Provide educational information Annual goal was not Annual goal was not Annual goal was not Utility for educational

to insured depository institutions established in 2001. established in 2002. established in 2003. tools was developed for

and their customers to help bankers and consumers.

them understand the rules for 

determining the amount of 

insurance coverage on deposit 

accounts. 

Risk Management, Safety and Soundness

Conduct on-site risk Conducted 2,575 or Conducted 2,534 or Conducted 2,421 Conducted 2,515

management examinations 97 percent of required 98 percent of required required safety and required safety and

to assess an FDIC-supervised safety and soundness safety and soundness soundness examinations soundness examinations

insured depository institution’s examinations. examinations. in accordance with FDIC in accordance with FDIC 

overall financial condition, policy. policy.

management practices and

policies, and compliance with

applicable regulations.

Safety and Soundness Enforcements Actions

Take prompt and effective Sixty-seven institutions Eighty-four institutions Seventy-three institutions Forty-four institutions

supervisory actions to address designated as problem designated as problem designated as problem designated as problem

problems identified during the (composite “4” or “5” (composite “4” or “5” (composite “4” or “5” (composite “4” or “5”

FDIC examinations of FDIC- rated). Fifty-six were rated). Forty-eight were rated). Fifty-eight with rated). Fifty-seven with

supervised institutions removed from problem removed from problem total assets of $6.98 total assets of $6.3

identified as problem insured status and 76 added. status and 63 added. billion were removed billion were removed

depository institutions. Monitor from problem status from problem status

FDIC-supervised insured Evaluations changed and 47 with total assets and 28 with total assets

depository institutions’ to monitor migration of $4.99 billion were of $4.8 billion were

compliance with formal of troubled banks. added. Additionally, the added. Additionally, the

and informal enforcement FDIC issued the following FDIC issued the following

actions. formal and informal formal and informal

enforcement actions: enforcement actions:

40 Cease and Desist 38 Cease and Desist

Orders and 157 Orders and 145

Memoranda of Memoranda of

Understanding. Understanding.
38

Compliance Examinations

Annual Goal 2001 Results 2002 Results 2003 Results 2004 Results

Conduct comprehensive Conducted 2,179 Conducted 1,840 Conducted 1,919 Conducted 2,136

compliance-only and CRA comprehensive comprehensive comprehensive comprehensive

examinations in accordance compliance-only and compliance-only and compliance-only and compliance-only and

with FDIC examination CRA examinations in CRA examinations in CRA examinations in CRA examinations in

frequency policy. accordance with FDIC accordance with FDIC accordance with FDIC accordance with FDIC

policy. There were no policy. There were no policy. There were no policy. There were no

delinquencies in 2001. delinquencies in 2002. delinquencies in 2003. delinquencies in 2004.

CRA Outreach

Provide effective outreach and Conducted 25 Money Money Smart The FDIC supplied Targets for the following 

technical assistance on topics Smart workshops with classes attended more than 111,000 were met: added 200 

related to CRA, fair lending, over 600 participants. by approximately copies of Money Smart new Money Smart

and community development. 2,800 participants. curriculum to Alliance members;

organizations. FDIC distributed 20,000 copies

sponsored 65 public of Money Smart

outreach initiatives, curriculum; additional

111 community 294,000 members

development activities, reached; and conducted

and 67 technical 125 outreach and

assistance activities. technical assistance

activities.

Compliance Enforcement Actions

Prompt and effective Six of seven institutions Eight of nine institutions The only “4” rated Of the five institutions

supervisory actions are had either been entered into a institution entered into rated “4” as of 

taken and monitored on all examined in the Memorandum of a Memorandum of December 31, 2004, 

institutions rated “4” or “5” preceding 12 months Understanding (MOU) Understanding (MOU) two entered into 

for compliance. or were still within the with the FDIC and the with the FDIC. Memorandums of

12 month time frame ninth was in the process Understanding with 

between examinations. of reviewing the the FDIC; and two are

One institution was recommended MOU subject to outstanding

pending resolution for at year-end. Cease and Desist Orders;

safety and soundness A Cease and Desist

reasons, and the Order for the fifth

compliance examination institution is expected 

was deferred pending to be issued during the 

resolution. first quarter of 2005.
39

Consumer Complaints and Inquiries

Annual Goal 2001 Results 2002 Results 2003 Results 2004 Results

Effectively respond to written FDIC sent 612 survey Annual goal revised Annual goal revised Annual goal revised

complaints and inquiries related cards to consumers and (see below). (see below). (see below).

to deposit insurance and bankers who contacted

consumer protection laws. the Washington Office

concerning inquiries and

complaints. Eighty-four 

(14 percent) of the cards

were returned to the

FDIC. Sixty-two percent 

of the responses rated 

the FDIC as “excellent” 

in timeliness of response.

Effectively meet the statutory The 2001 annual FDIC received 8,368 FDIC received 8,010 FDIC received 8,742

mandate to investigate performance goal was consumer complaints consumer complaints consumer complaints,

and respond to consumer not compatible to the and closed 95 percent and closed 99 percent closing 95 percent of 

complaints about FDIC- current annual goal. of them. Of the of them. Of the them. Of the closed 

supervised financial institutions. complaints closed, complaints closed, complaints, 95 percent

(Revised–2002) 94 percent were closed 94 percent were closed were closed within

within policy time frames. within policy time frames. policy time frames.

Asset Management

Value, manage and market For three institutions that For all 11 institutions that For all three institutions Five financial institutions

assets of the failed institutions failed, the FDIC marketed failed, at least 87 percent that failed, at least 98 reached their 90-day

and their subsidiaries in a timely 100 percent of the of all marketable assets percent of all marketable threshold during 2004.

manner to maximize net return. marketable assets. The were marketed within assets were marketed One hundred percent 

remaining institution the 90-day time frame, within the 90-day time of all marketable assets

was placed into thus exceeding the frame, thus exceeding were marketed within

conservatorship. Loan target of 85 percent. the target of 85 percent. the 90-day time frame.

pools, servicing operations

and residuals that totaled

in excess of the 80 percent

target were marketed

within the 90-day time 

frame.

Least- Cost Resolution

Market to all known qualified There were four failures There were 11 failures There were three failures There were four failures

and interested potential in 2001. One hundred in 2002. One hundred in 2003. One hundred in 2004. One hundred

assuming institutions. percent of the qualified percent of the qualified percent of the qualified percent of the qualified

potential bidders were potential bidders were bidders were contacted. bidders were contacted

contacted. contacted. for the sale of three

failed institutions. One

failed institution was

not offered for sale.
40

Least-Cost Resolution (continued)

Annual Goal 2001 Results 2002 Results 2003 Results 2004 Results

Conduct investigations of all Five of nine institutions Two of six institutions Four of ten institutions All five institutions that

potential professional liability that reached the 18-month that reached the 18-month that reached the 18-month reached the 18-month

claim areas in all failed insured milestone had 100 percent milestone during 2002 milestone during 2003 milestone during 2004

depository institutions. Decide of professional liability had 100 percent of had 100 percent of had 100 percent of

to close or pursue each investigations completed. professional liability professional liability professional liability

claim as promptly as possible, investigations completed. investigations completed. investigations 

considering the size and The other four institutions The other six institutions completed, meeting 

complexity of the institution. had at least 80 percent had at least 80 percent the goal of 80 percent. 

of professional liability of professional liability

investigations completed, investigations completed,

meeting the goal of meeting the goal of

80 percent. 80 percent.

Manage the receivership Fifty-two out of the 76 For the eight failures For the seven failures For the four failures

estate and its subsidiaries targeted receiverships from 1999 that matured that occurred during that occurred during

toward an orderly termination. were terminated in 2001. in 2002, the FDIC 2000 that matured in 2001 that matured in

(Revised–2001) In mid-2001, the target terminated six 2003, the FDIC 2004, the FDIC

of 76 terminations was receiverships, meeting terminated four terminated three

revised to 36. The pace the target to terminate receiverships, below receiverships, meeting

of termination was 75 percent within three the target to terminate the target to terminate

slowed by impediments years of failure. 75 percent within three 75 percent within three

that represented material years of failure. years of failure date.

financial or legal risks

to the FDIC.
41

★

★

★

★

Program Evaluation

During 2004, the FDIC completed evaluations of programs designed to achieve the strategic 

objectives set forth in the Receivership Management area of the FDIC’s 2004 – 2009 Strategic 

Plan. The following section highlights the issues evaluated and summarizes the results of this 

evaluation.

Strategic The FDIC resolves failed insured depository institutions in the least-costly manner.

Objective

Issues evaluated What is the process for marketing failing institutions?

How is a listing of qualified and interested potential bidders generated?

Findings During 2004, four financial institutions failed. Three of the four were marketed using a Web -

based automated notification system. The fourth was not marketed due to the unique situation 

involving allegations of fraud and little advance notice of the closing. The FDIC maintains 

a database of qualified and interested potential bidders consisting of financial institutions. 

In composing the potential bidders list, the FDIC takes into account the failed institution’s 

geographic location, competitive environment, minority-owned status, financial condition, asset 

size, capital level and regulatory ratings. By using a Web-based system, the FDIC can market 

to a potential bidder both the failed institution and its assets more effectively and efficiently.

Strategic Receiverships are managed to maximize net return toward an orderly and timely 

Objective termination. 

Issues evaluated How are net returns maximized?

What constitutes orderly and timely termination?

Findings For 2004, the FDIC’s goal was to market 85 percent of book value of a failed institution’s 

marketable assets within 90 days of failure. Five financial institutions reached their 90-day 

threshold during this time. In each instance, 100 percent of the marketable assets were marketed

within 90 days. Returning failed bank assets to the private sector quickly allows the FDIC to 

maximize net recoveries and minimize any disruption to the local community. The oversight and 

prompt termination of the receivership preserves value for the uninsured depositors and other 

receivership claimants by reducing overhead and other holding costs. The FDIC uses a number 

of information technology applications, including Internet auctions, to facilitate the management 

and marketing of assets.

Strategic Potential recoveries, including claims against professionals, are investigated and 

Objective are pursued and resolved in a fair and cost-effective manner. 

Issues evaluated How are potential recoveries identified and investigated?

Findings The FDIC follows extensive guidelines on how to conduct an investigation of a failed institution

to identify potential claims and recovery sources. Every aspect of the process is extensively 

documented and reviewed, from pre-closing steps, to previewing potential claims and discovering

and preserving sources of recovery for these claims, through tracking costs and recoveries. 

In addition, the FDIC keeps careful track of investigations at a high level through the Management

Control Plan, which serves to maintain a record of each investigation and keep risks in check. 

Such risks principally arise from the failure to maintain accurate reports and records necessary 

to substantiate claims.

★