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GAO-11-528R: 

United States Government Accountability Office: 
Washington, DC 20548: 

April 27, 2011: 

The Honorable Van Zeck: 
Commissioner: 
Bureau of the Public Debt: 

Subject: Bureau of the Public Debt: Areas for Improvement in 
Information Systems Controls: 

Dear Mr. Zeck: 

In connection with fulfilling our requirement to audit the financial 
statements of the U.S. government,[Footnote 1] we audited and reported 
on the Schedules of Federal Debt Managed by the Bureau of the Public 
Debt (BPD) for the fiscal years ended September 30, 2010 and 2009. 
[Footnote 2] As part of these audits, we performed a review of 
information systems controls over key BPD financial systems. 

As we reported in connection with our audit of the Schedules of 
Federal Debt for the fiscal years ended September 30, 2010 and 2009, 
we concluded that BPD maintained, in all material respects, effective 
internal control over financial reporting relevant to the Schedule of 
Federal Debt as of September 30, 2010, that provided reasonable 
assurance that misstatements, losses, or noncompliance material in 
relation to the Schedule of Federal Debt would be prevented, or 
detected and corrected on a timely basis. However, we identified 
information systems deficiencies affecting internal control over 
financial reporting, which, while we do not consider them to be 
collectively either a material weakness or significant deficiency, 
nevertheless warrant BPD management's attention and action.[Footnote 3] 

This report presents the control deficiencies we identified during our 
fiscal year 2010 testing of information systems controls that support 
key BPD automated financial systems relevant to BPD's Schedule of 
Federal Debt. This report also includes the results of our follow-up 
on the status of BPD's corrective actions to address information 
systems control-related recommendations contained in our prior years' 
reports and open as of September 30, 2009. In a separately issued 
Limited Official Use Only report, we communicated detailed information 
regarding our findings to BPD management. We also assessed information 
systems controls over key financial systems that the Federal Reserve 
Banks (FRB) maintain and operate on behalf of BPD. We issued a 
separate report to the Board of Governors of the Federal Reserve
System on the results from that assessment. 

Results in Brief: 

Our fiscal year 2010 audit procedures identified four new general 
information systems control deficiencies related to access controls, 
configuration management, and segregation of duties. We made six 
recommendations to address these control deficiencies. 

None of the control deficiencies we identified represented significant 
risks to the BPD financial systems. The potential effect of such 
control deficiencies on financial reporting relevant to the Schedule 
of Federal Debt was mitigated by BPD's physical security measures and 
a program of monitoring user and system activity, as well as 
compensating management and reconciliation controls designed to detect 
potential misstatements in the Schedule of Federal Debt. 

In addition, during our fiscal year 2010 follow-up on the status of 
BPD's corrective actions to address 11 open recommendations related to 
general information systems control deficiencies identified in prior 
years' audits, we determined that as of September 30, 2010, corrective 
action on 9 of the 11 recommendations was completed, while corrective 
action was in progress on the 2 remaining open recommendations related 
to access controls. 

BPD provided comments on the detailed findings and recommendations in 
the separately issued Limited Official Use Only report. In those 
comments, the Commissioner of BPD stated that of the six findings open 
as of September 30, 2010, one has been completely resolved and 
corrective actions for the remaining five are planned or in progress. 
The Commissioner further commented that BPD intends to implement 
corrective actions for two of the five remaining findings by August 
2011 and for the other three by December 2011. 

Background: 

The Department of the Treasury (Treasury) is authorized by Congress to 
borrow money backed by the full faith and credit of the United States 
to fund federal operations. Treasury is responsible for prescribing 
the debt instruments and otherwise limiting and restricting the amount 
and composition of the debt. BPD, an organizational entity within the 
Fiscal Service of the Treasury, is responsible for issuing and 
redeeming debt instruments, paying interest to investors, and 
accounting for the resulting debt. In addition, BPD has been given the 
responsibility for issuing Treasury securities to trust funds for 
trust fund receipts not needed for current benefits and expenses. 

As of September 30, 2010 and 2009, federal debt managed by BPD totaled 
about $13.5 trillion and $11.9 trillion, respectively, primarily for 
moneys borrowed to fund the federal government's operations. These 
balances consisted of approximately (1) $9.0 trillion and $7.6 
trillion of debt held by the public as of September 30, 2010 and 2009, 
respectively, and (2) $4.5 trillion and $4.3 trillion of 
intragovernmental debt holdings as of September 30, 2010 and 2009, 
respectively. Total interest expense on federal debt managed by BPD 
for fiscal years 2010 and 2009 was about $413 billion and $381 
billion, respectively. 

BPD relies on a number of interconnected financial systems and 
electronic data to process and track the money that it borrows and to 
account for the securities it issues. Many of the FRBs provide fiscal 
agent services on behalf of BPD. Such services primarily consist of 
issuing, servicing, and redeeming Treasury securities held by the 
public and handling the related transfers of funds. FRBs use a number 
of key financial systems to process debt-related transactions. 
Detailed data initially processed at the FRBs are summarized and then 
forwarded electronically to BPD's data center for matching, 
verification, and posting to the general ledger. 

Objectives, Scope, and Methodology: 

Our objectives were to evaluate information systems controls over key 
financial management systems maintained and operated by, and on behalf 
of, BPD relevant to the Schedule of Federal Debt and to determine the 
status of BPD's corrective actions to address information systems 
control-related recommendations in our prior years' reports for which 
actions were not complete as of September 30, 2009. Our evaluation of 
information systems controls was conducted using the Federal Information
System Controls Audit Manual (FISCAM).[Footnote 4] 

To evaluate information systems controls, we identified and reviewed 
BPD's information systems control policies and procedures, observed 
controls in operation, conducted tests of controls, and held 
discussions with officials at the BPD data center to determine whether 
controls were adequately designed, implemented, and operating 
effectively. 

The scope of our general information systems controls work for fiscal 
year 2010 included (1) following up on open recommendations from our 
prior years' reports and (2) using a risk-based approach to testing 
the five FISCAM general control areas related to the systems in which 
the applications operate and other critical control points in the 
systems or networks that could impact the effectiveness of the 
information systems controls at BPD in the current year. In addition, 
we performed security diagnostics and vulnerability assessment testing 
of BPD's internal information system environment. 

We determined whether relevant application controls were appropriately 
designed and implemented, and then performed tests to determine 
whether the application controls were operating effectively. We 
reviewed five key BPD applications to determine whether the 
application controls were designed and operating effectively to 
provide reasonable assurance that: 

* all transactions that occurred were input into the system, accepted 
for processing, processed once and only once by the system, and 
properly included in output; 

* transactions were properly recorded in the proper period, key data 
elements input for transactions were accurate, data elements were 
processed accurately by applications that produce reliable results, 
and output was accurate; 

* all recorded transactions actually occurred, related to the 
organization, and were properly approved in accordance with 
management's authorization, and output contained only valid data; 

* application data and reports and other output were protected against 
unauthorized access; and; 

* application data and reports and other relevant business information 
were readily available to users when needed. 

We also reviewed the application information systems control audit 
documentation from the work performed by the Treasury Office of 
Inspector General's contractor on two other key BPD applications. 

Because the FRBs are integral to the operations of BPD, we assessed 
the information systems controls over financial systems that the FRBs 
maintain and operate relevant to the Schedule of Federal Debt. This 
included using a risk-based approach to testing the five FISCAM 
general control areas related to the systems in which the
applications operate and other critical control points in the systems 
or networks that could impact the effectiveness of the information 
systems controls. We also evaluated the relevant application controls 
over four key financial applications maintained and operated by the 
FRBs. We issued a separate report to the Board of Governors of the 
Federal Reserve System on the results from that assessment. 

The independent public accounting (IPA) firm of Cotton and Company LLP 
evaluated and tested certain BPD information systems controls, 
including the follow-up on the status of BPD corrective actions during 
fiscal year 2010 to address open recommendations from our prior years' 
reports. We agreed on the scope of the audit work, monitored the IPA 
firm's progress, and reviewed the related audit documentation to 
determine that the firm's findings were adequately supported. 

During the course of our work, we communicated our findings to BPD 
management. We plan to follow up to determine the status of corrective 
actions taken for matters open as of September 30, 2010, during our 
audit of the fiscal year 2011 Schedule of Federal Debt. 

We performed our work at the BPD data center where the operations of 
the systems we reviewed are supported. Our work was performed from 
February 2010 through October 2010 in accordance with U.S. generally 
accepted government auditing standards. We believe that our audit 
provided a reasonable basis for our conclusions in this report. 

As noted above, we obtained agency comments on the detailed findings 
and recommendations in a draft of the separately issued Limited 
Official Use Only report. BPD's comments are summarized in the Agency 
Comments and Our Evaluation section of this report. 

Assessment of BPD's Information Systems Controls: 

General information systems controls are the structure, policies, and 
procedures that apply to an entity's overall computer operations. 
General information systems controls establish the environment in 
which application systems and controls operate. They include security 
management, access controls, configuration management, segregation of 
duties, and contingency planning. An effective general information 
systems control environment (1) provides a framework and continuing 
cycle of activity for managing risk, developing security policies, 
assigning responsibilities, and monitoring the adequacy of the 
entity's computer-related controls to ensure that an adequate security 
management program is in place; (2) limits or detects access to 
computer resources (data, programs, equipment, and facilities), 
thereby protecting them against unauthorized modification, loss, and 
disclosure; (3) prevents unauthorized changes to information system 
resources (for example, software programs and hardware configurations) 
and provides reasonable assurance that systems are configured and 
operating securely and as intended; (4) includes policies, procedures, 
and an organizational structure to manage who can control key aspects 
of computer-related operations; and (5) protects critical and 
sensitive data, and provides for critical operations to continue 
without disruption or be promptly resumed when unexpected events occur. 

During our fiscal year 2010 testing, we identified opportunities to 
strengthen certain information systems controls that support key BPD 
financial systems relevant to BPD's Schedule of Federal Debt. 
Specifically, we identified four new general information systems 
control deficiencies related to access controls, configuration 
management, and segregation of duties. 

Access controls are important because they limit access or detect 
inappropriate access to computer resources (data, equipment, and 
facilities), thereby protecting them from unauthorized modification, 
loss, and disclosure. Such controls include logical access controls 
and physical access controls. The new access control deficiencies we 
identified during fiscal year 2010 related to logical access controls.
Logical access controls require users to authenticate themselves 
through the use of passwords or other identifiers, and limit the files 
and other resources that authenticated users can access and the 
actions that they can execute based on a valid need that is determined 
by assigned official duties. 

Configuration management is important because it involves the 
identification and management of security features for all hardware, 
software, and firmware components of an information system at a given 
point and systematically controls changes to that configuration during 
the system's life cycle. At each system sublevel (i.e., network, 
operating systems, and infrastructure applications), configuration 
management controls provide reasonable assurance that only authorized 
changes are made to such critical components. In addition, 
configuration management controls provide reasonable assurance that 
applications and changes to the applications go through a formal, 
documented systems development process that identifies all changes to 
the baseline configuration. 

Segregation of duties is important because work responsibilities 
should be segregated so that one individual does not control all 
critical stages of a process. Segregation of duties is achieved by 
splitting responsibilities between two or more organizational groups. 
In addition, dividing duties this way diminishes the likelihood that 
errors and wrongful acts will go undetected because the activities of 
one group or individual will serve as a check on the activities of the 
other. 

In a separately issued Limited Official Use Only report, we 
communicated detailed information regarding our new findings to BPD 
management and made six detailed recommendations. 

In addition, our fiscal year 2010 follow-up on the status of actions 
taken to address unresolved general information systems control 
deficiencies we identified in our prior years' audits for which 
actions were not complete as of September 30, 2009, found that BPD 
completed corrective actions on 9 of the 11 open recommendations, 
while corrective action was in progress on the two remaining open 
recommendations related to access controls. Although BPD management 
has made progress in addressing the remaining two general information 
systems control deficiencies, additional actions are needed. 

None of the control deficiencies we identified represented significant 
risks to the BPD financial systems. The potential effect of such 
control deficiencies on financial reporting relevant to the Schedule 
of Federal Debt was mitigated by BPD's physical security measures and 
a program of monitoring user and system activity, as well as 
compensating management and reconciliation controls designed to detect 
potential misstatements in the Schedule of Federal Debt. Nevertheless, 
these deficiencies warrant management's attention and action to limit 
the risk of unauthorized access, loss, or disclosure; modification of 
sensitive data and programs; and disruption of critical operations. 

Assessment of FRB Information Systems Controls: 

Because the FRBs are integral to the operations of BPD, we assessed 
information systems controls over key financial systems maintained and 
operated by the FRBs on behalf of BPD. We issued a separate report to 
the Board of Governors of the Federal Reserve System on the results 
from that assessment. 

Conclusion: 

BPD has made significant progress in addressing the open information 
systems control recommendations from our prior years' audits, and 
while actions are still needed in two control areas, it has corrective 
actions under way or planned. Our fiscal year 2010 audit also 
identified four new general information systems control deficiencies 
related to access controls, configuration management, and segregation 
of duties. 

Recommendation for Executive Action: 

We recommend that the Commissioner of the Bureau of the Public Debt 
direct the appropriate BPD officials to implement the six new detailed 
recommendations presented in the separately issued Limited Official 
Use Only report. 

Agency Comments and Our Evaluation: 

BPD provided comments on the detailed findings and recommendations in 
the separately issued Limited Official Use Only report. In those 
comments, the Commissioner of BPD stated that of the six findings open 
as of September 30, 2010, one has been completely resolved and 
corrective actions for the remaining five are planned or in progress. 
The Commissioner also stated that BPD intends to implement corrective 
actions for two of the five remaining findings by August 2011 and for 
the other three by December 2011. We plan to follow up to determine 
the status of corrective actions taken for these matters during our 
audit of the fiscal year 2011 Schedule of Federal Debt. 

In the separately issued Limited Official Use Only report, we noted 
that the head of a federal agency is required by 31 U.S.C. § 720 to 
submit a written statement on actions taken on our recommendations to 
the Senate Committee on Homeland Security and Governmental Affairs and 
to the House Committee on Oversight and Government Reform not later 
than 60 days after the date of the Limited Official Use Only report. A 
written statement must also be sent to the Senate and House Committees 
on Appropriations with the agency's first request for appropriations 
made more than 60 days after the date of that report. In the Limited 
Official Use Only report, we also requested a copy of your responses. 

We are sending copies of this report to interested congressional 
committees, the Secretary of the Treasury, the Inspector General of 
the Department of the Treasury, and the Director of the Office of 
Management and Budget. This report also is available at no charge on 
the GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you have any questions regarding this report, please contact me at 
(202) 512-3406 or engelg@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are Jeffrey L. Knott and Dawn B. Simpson, Assistant Directors; 
Edmund F. Fernandez; and George C. Kovachick. 

Sincerely yours, 

Signed by: 

Gary T. Engel: 
Director: 
Financial Management and Assurance: 

[End of section] 

Footnotes: 

[1] 31 U.S.C. § 331(e)(2). As a bureau within the Department of the 
Treasury, federal debt and related activity and balances are also 
significant to the consolidated financial statements of the Department 
of the Treasury (see 31 U.S.C. § 3515(b)). 

[2] GAO, Financial Audit: Bureau of the Public Debt's Fiscal Years 
2010 and 2009 Schedules of Federal Debt, [hyperlink, 
http://www.gao.gov/products/GAO-11-52] (Washington, D.C.: Nov. 8, 
2010). 

[3] A material weakness is a deficiency, or a combination of 
deficiencies, in internal control such that there is a reasonable 
possibility that a material misstatement of the entity's financial 
statements will not be prevented, or detected and corrected on a 
timely basis. A significant deficiency is a deficiency, or combination 
of deficiencies, in internal control that is less severe than a 
material weakness, yet important enough to merit attention by those 
charged with governance. A deficiency in internal control exists when 
the design or operation of a control does not allow management or 
employees, in the normal course of performing their assigned 
functions, to prevent, or detect and correct, misstatements on a 
timely basis. 

[4] GAO, Federal Information System Controls Audit Manual, [hyperlink, 
http://www.gao.gov/products/GAO-09-232G] (Washington, D.C.: February 
2009). 

[End of section] 

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