This is the accessible text file for GAO report number GAO-11-398R 
entitled 'Management Report: Opportunities for Improvement in the 
Federal Housing Finance Agency's Internal Controls and Accounting 
Procedures' which was released on April 29, 2011. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

GAO-11-398R: 

United States Government Accountability Office: 
Washington, DC 20548: 

April 29, 2011: 

Mr. Edward J. DeMarco: 
Acting Director: 
Federal Housing Finance Agency: 

Subject: Management Report: Opportunities for Improvement in the 
Federal Housing Finance Agency's Internal Controls and Accounting 
Procedures: 

Dear Mr. DeMarco: 

In November 2010, we issued our opinion on the Federal Housing Finance 
Agency's (FHFA) fiscal years 2010 and 2009 financial statements. Our 
report also included our opinion on the effectiveness of FHFA's 
internal control over financial reporting as of September 30, 2010, 
and our evaluation of FHFA's compliance with provisions of selected 
laws and regulations for the fiscal year ended September 30, 2010. 
[Footnote 1] 

The Housing and Economic Recovery Act of 2008 (HERA) created FHFA and 
gave it responsibility for, among other things, the supervision and 
oversight of the Federal National Mortgage Association (Fannie Mae), 
the Federal Home Loan Mortgage Corporation (Freddie Mac), and the 12 
federal home loan banks. Specifically, FHFA was assigned 
responsibility for ensuring that the regulated entities operate in a 
fiscally safe and sound manner, including maintenance of adequate 
capital and internal controls, in carrying out their housing and 
community-development finance mission. HERA requires FHFA to annually 
prepare financial statements, and requires GAO to audit these 
statements. 

The purpose of this report is to present additional information on the 
internal control and accounting procedure issues we identified during 
our audit of FHFA's fiscal year 2010 financial statements and to 
provide our recommended actions to address those issues. We are making 
three recommendations for strengthening FHFA's internal controls and 
accounting procedures. In addition, we are providing an update on the 
status of recommendations we made to address internal control issues 
identified during our audit of FHFA's fiscal year 2009 financial 
statements as reported in our June 3, 2010, management report on 
internal controls and accounting procedures[Footnote 2] and our April 
30, 2010, report on controls related to information security.[Footnote 
3] 

Results in Brief: 

During our audit of FHFA's fiscal years 2010 and 2009 financial 
statements, we identified two internal control issues that could 
adversely affect FHFA's ability to meet its internal control 
objectives. We do not consider these issues to represent material 
weaknesses or significant deficiencies[Footnote 4] in relation to 
FHFA's financial statements. Nonetheless, we believe they warrant 
management's attention and action. These issues concern necessary 
controls to ensure: 

* completing proper documentation and obtaining approval prior to 
disposing of capitalized assets and: 

* verifying vendor invoices for accuracy prior to payment. 

These issues increase the risk of FHFA not preventing or promptly 
detecting and correcting misappropriation of assets or misstatements 
in its financial statements. 

At the end of our discussion of each of these issues in the sections 
that follow, we present our recommendations for strengthening FHFA's 
internal controls over disposals of capitalized assets and vendor 
invoice payment processing. These recommendations are intended to 
improve management's oversight and controls and minimize the risk of 
misappropriation of assets and misstatements in FHFA's accounts and 
financial statements. 

As of the completion of our fiscal year 2010 audit on November 9, 
2010, FHFA had taken action to fully address 6 of the 22 internal 
control-related recommendations from our fiscal year 2009 audit (see 
enclosures I and II). FHFA also took action to address the three 
internal control and accounting procedures-related recommendations 
that remain open, but more work is needed to fully resolve the 
underlying control issues. For the 13 recommendations related to 
information systems controls that remain open, FHFA had actions in 
process as of November 9, 2010, intended to address the related 
control issues. We did not identify any new weaknesses concerning 
information security controls during our fiscal year 2010 audit. 

In its comments, FHFA agreed with our recommendations and described 
actions it has taken, or plans to take, to address the control issues 
described in this report. At the end of our discussion of each issue 
in this report, we have summarized FHFA's related comments. We will 
evaluate the effectiveness of FHFA's corrective actions as part of our 
fiscal year 2011 audit. We have also reprinted FHFA's comments in 
their entirety in enclosure III. 

Scope and Methodology: 

As part of our audit of FHFA's fiscal years 2010 and 2009 financial 
statements, we evaluated FHFA's internal controls and tested its 
compliance with selected provisions of laws and regulations. We 
designed our audit procedures to test relevant controls over financial 
reporting, including those designed to provide reasonable assurance 
that transactions are properly recorded, processed, and summarized to 
permit the preparation of FHFA's financial statements in conformity 
with U.S. generally accepted accounting principles. 

We performed our audit of FHFA's fiscal years 2010 and 2009 financial 
statements 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. Further details on our audit 
methodology are presented in enclosure IV. 

Disposal of Capitalized Property and Equipment: 

During our testing of FHFA's property and equipment disposal 
transactions conducted as part of our fiscal year 2010 audit, we found 
that FHFA did not follow its procedures for disposing of capitalized 
property and equipment. Specifically, FHFA did not complete a Transfer 
of Property Receipt Form or obtain the proper approval for all 
capitalized property and equipment disposals made in fiscal year 2010. 

Standards for Internal Control in the Federal Government[Footnote 5] 
provides that agencies are to maintain appropriate documentation of 
transactions and that agencies are to ensure proper execution of 
transactions. According to FHFA's Property Management Policy, which is 
included in its Administrative Accounting Manual, a Transfer of 
Property Receipt form[Footnote 6] must be completed for the disposal 
of property. The Property Management Policy also states that the Chief 
Information Officer is responsible for approving the disposal of 
information technology equipment and the Chief Administrative Officer 
is responsible for approving the disposal of all other assets. FHFA 
did not enforce the internal control procedures documented in its 
Property Management Policy for the proper disposal of property. In 
addition, while FHFA's Property Management Policy does require 
approval for the disposal of capitalized assets, it does not specify 
how the approval will be documented. In reviewing all seven 
capitalized asset disposals that occurred during fiscal year 2010, 
which consisted of five catalysts,[Footnote 7] a printer, and a 
mailing station, we found that none had a completed Transfer of 
Property Receipt form nor any documentation demonstrating that 
approval was obtained prior to disposal of the assets. 

Deficiencies in procedures covering the disposal of capitalized assets 
can lead to the misstatement of assets in the financial statements and 
the underlying records FHFA maintains to support its capitalized 
assets. In addition, not adhering to the established controls over the 
disposal of property increases the risk of theft or loss of FHFA 
assets. 

Recommendations: 

We recommend that you direct the Chief Financial Officer to: 

* establish a mechanism to monitor compliance with policies and 
procedures surrounding the proper disposal of capitalized property and 
equipment and: 

* update the Property Management Policy to include procedures for how 
to properly document approval before disposal of FHFA assets. 

FHFA Comments: 

FHFA agreed with the recommendations and cited actions it has taken, 
or intends to take, to address this internal control issue. For 
example, FHFA stated that property management processes have been 
outlined and that property management procedures will be developed 
that will include strengthening controls over the disposal of property 
and equipment. 

Invoice Payment Procedures: 

During our testing of nonpayroll[Footnote 8] expense transactions 
conducted as part of our fiscal year 2010 audit, we found that FHFA 
did not always properly verify vendor invoice amounts prior to 
payment. Specifically, in reviewing one of our test transactions, we 
found a discrepancy with the number of hours billed by a law firm. The 
invoice included a summary page that documented the total number of 
hours worked by each individual for a specific period of time. The 
invoice also contained the detail that was supposed to support the 
total hours recorded on the summary page. In reviewing the detailed 
supporting documentation, we found that the summary page contained 
about 4 more hours for a specific law firm employee than was shown in 
the detailed supporting documentation. FHFA based the payment on the 
hours shown on the summary page and did not verify these amounts 
against the supporting documentation. After we raised this issue with 
FHFA officials, they reviewed all of the invoices received from two of 
FHFA's vendors that provide legal services to the agency. From this 
review, FHFA discovered one overpayment in the amount of $424 for 
which FHFA received a credit on its next invoice. 

Standards for Internal Control in the Federal Government[Footnote 9] 
provides that agencies are to ensure accurate and timely recording of 
transactions and events. FHFA's Administrative Accounting Manual 
contains Invoice and Payment Desktop Procedures that describe the 
procedures for processing payments for FHFA. Although these procedures 
contain detailed steps for invoice processing and payment, they do not 
require that invoiced amounts be confirmed against supporting 
documentation provided with the invoice prior to payment. 

Deficiencies in controls over FHFA's invoice payment processing 
procedures can increase the risk of it making improper payments and 
misstating expenses in its financial statements. 

Recommendation: 

We recommend that you direct the Chief Financial Officer to enhance 
FHFA's Invoice and Payment Desktop Procedures to include detailed 
instructions on how to verify the accuracy of invoice amounts prior to 
payment. 

FHFA Comments: 

FHFA stated that it agreed that additional guidance needs to be given 
to invoice approvers/contracting officer technical representatives 
(COTR) and cited actions it has taken, or intends to take, to address 
this internal control issue. For example, FHFA stated that it and the 
Bureau of the Public Debt (BPD), FHFA's accounting services provider, 
alerted invoice approvers/COTRs by means of written correspondence 
that an error had been identified during the fiscal year 2010 
financial audit and instructed them on the necessity of careful 
verification of billed amounts and invoice details. FHFA outlined 
further actions to be taken, including conducting training, posting 
guidance on its intranet, and conducting verification reviews. 

Status of Fiscal Year 2009 Audit Recommendations: 

During our audit of FHFA's fiscal year 2009 financial statements, we 
identified seven internal control issue areas and made 22 
recommendations for corrective actions. Of the 22 recommendations we 
made for corrective actions, 6 related to internal control and 
accounting procedures issues reported in our June 3, 2010, management 
report[Footnote 10] and 16 related to information security control 
issues reported in our April 30, 2010, report.[Footnote 11] During our 
audit of FHFA's fiscal years 2010 and 2009 financial statements, we 
found that FHFA had taken action to fully address 3 of the 6 
recommendations related to internal control and accounting procedure 
issues from our prior audit (see enclosure I). The 3 recommendations 
that remained open as of November 9, 2010, the completion date of our 
fiscal year 2010 financial audit, relate to undelivered orders 
[Footnote 12] and expense accruals. Although FHFA improved its 
Administrative Accounting Manual by incorporating our recommendations 
related to the accurate calculation of undelivered orders balances, we 
continued to identify errors during the testing of undelivered orders 
balances at June 30, 2010. Even though our testing did not identify 
any errors in the undelivered orders balances at September 30, 2010, 
the presence of errors during the year indicates more efforts are 
needed to routinely enforce procedures related to the calculation of 
undelivered orders balances. In addition, FHFA took steps to implement 
our recommendation related to the calculation of expense accruals by 
providing training to staff that included examples of expenses that 
should and should not be accrued at the end of an accounting period. 
However, we continued to find some errors in the amounts accrued at 
September 30, 2010. Although these errors were not material to FHFA's 
fiscal year 2010 financial statements, the continued presence of such 
errors indicates that further efforts are needed to more effectively 
enforce procedures related to the calculation of expense accruals. 

During our fiscal year 2010 audit, we also found that FHFA took action 
to fully address 3 of the 16 recommendations related to information 
systems control issues from our prior audit (see enclosure II). The 13 
recommendations that remained open as of November 9, 2010, relate to 
logical-access controls, physical access controls, and FHFA's 
information security program. While FHFA has made progress in each of 
these areas, our fiscal year 2010 testing revealed that additional 
work is required before these issues are fully addressed. For example, 
FHFA developed logical-access control procedures (the first step in 
addressing the logical-access control recommendations), developed a 
physical-security policy, and made progress in developing multiple 
policies and procedures related to its information security program. 
Although FHFA has made progress developing policies and procedures in 
these information systems areas, full implementation of certain 
procedures is not yet complete. During our fiscal year 2011 audit, we 
will assess the implementation of any new procedures employed by FHFA 
to address the recommendations related to information systems control 
issues. 

This report contains recommendations to you. The head of a federal 
agency is required by 31 U.S.C. § 720 to submit a written statement on 
actions taken on these recommendations. You should submit your 
statement to the Senate Committee on Homeland Security and 
Governmental Affairs and the House Committee on Oversight and 
Government Reform within 60 days of the date of this report. A written 
statement must also be sent to the House and Senate Committees on 
Appropriations with the agency's first request for appropriations made 
more than 60 days after the date of this report. 

This report is intended for use by FHFA management. We are sending 
copies of this report to the Chairman and Ranking Member of the Senate 
Committee on Banking, Housing, and Urban Affairs; the Chairman and 
Ranking Member of the House Committee on Financial Services; the 
Chairman of the Federal Housing Finance Oversight Board; the Secretary 
of the Treasury; the Secretary of Housing and Urban Development; the 
Chairman of the Securities and Exchange Commission; the Director of 
the Office of Management and Budget; and other interested parties. In 
addition, this report will be available at no charge on GAO's Web site 
at [hyperlink, http://www.gao.gov]. 

We acknowledge and appreciate the cooperation and assistance provided 
by FHFA management and staff during our audit of FHFA's fiscal years 
2010 and 2009 financial statements. If you have any questions about 
this report or need assistance in addressing these issues, please 
contact me at (202) 512-3406 or sebastians@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 Peggy Smith, Assistant Director, and 
Megan McGehrin, Senior Auditor. 

Sincerely yours, 

Signed by: 

Steven J. Sebastian: 
Director: 
Financial Management and Assurance: 

Enclosures - 4: 

[End of section] 

Enclosure I: Status of Recommendations from GAO's 2009 Management 
Report: 

This enclosure presents the status of the six recommendations 
initially reported in GAO's June 3, 2010, management report. The 
recommendations are grouped according to deficiency areas specified in 
that management report. 

Table 1: Status of Recommendations from GAO's 2009 Management Report 
at the End of GAO's Audit of the Federal Housing Finance Agency's 
(FHFA) Fiscal Year 2010 Financial Statements: 

Audit area: Undelivered orders: 

1. Enhance the Administrative Accounting Manual by incorporating 
specific, detailed steps for the contracting officer technical 
representatives (COTR) review of contract balances, including the use 
of the open obligations report provided by the Bureau of the Public 
Debt in the COTR review process; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

2. Enhance the Administrative Accounting Manual by including specific, 
detailed steps on when and how to properly account for obligating and 
deobligating contract amounts; 
Year initially reported: 2009; 
Status of corrective action: In progress:. 

Audit area: Documentation and review process for receipt and 
acceptance of goods and services: 

3. Revise the Administrative Accounting Manual to provide for 
specific, detailed steps for obtaining and maintaining documentation 
as evidence of receipt and acceptance; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

Audit area: Expense accruals: 

4. Enhance training materials related to accruals to include examples 
of expenses that should and should not be accrued at the end of an 
accounting period; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

Audit area: Classification and recording of costs: 

5. Issue a memorandum reiterating policies surrounding the accurate 
recording and review of transactions to all staff involved in the 
process; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

6. Update the Administrative Accounting Manual to include the roles 
and responsibilities of the Manager of Financial Management Operations 
and secondary reviewers regarding the identifying and recording of 
capitalized transactions; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

Source: GAO analysis of FHFA data. 

[End of table] 

[End of Enclosure I] 

Enclosure II: Status of Recommendations from GAO's 2009 Information 
Security Management Report: 

This enclosure presents the status of the 16 recommendations initially 
reported in GAO's April 30, 2010, information security management 
report. The recommendations are grouped according to deficiency areas 
specified in that management report. 

Table 2: Status of Recommendations from GAO's 2009 Information 
Security Management Report at the End of GAO's Audit of the Federal 
Housing Finance Agency's (FHFA) Fiscal Year 2010 Financial Statements: 

Audit area: Logical access controls: 

1. Maintain network access authorizations for every agency network 
user; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

2. Review current access to network files and directories containing 
confidential information and restrict access to personnel with an 
authorized need to access that information; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

3. Continuously monitor use of privileged accounts on systems 
throughout the network so inadvertent or extended use of privileged 
access is promptly detected and removed; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

Audit area: Controls over physical access: 

4. Secure areas that contain information technology equipment and 
sensitive information; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

5. Complete sufficient physical-security policies to address 
protection of agency assets, including incident response, access 
authorizations, and environmental safety controls; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

6. Perform physical-security risk assessments at key facilities; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

7. Develop, document, and implement monitoring procedures to ensure 
that physical access authorizations to secure areas containing 
sensitive computer resources, including server rooms, and sensitive 
information are current and controlled; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

8. Develop, document, and implement monitoring procedures and install 
appropriate equipment to ensure that FHFA can detect and respond to 
potential physical-security incidents; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

9. Implement and enforce visitor-control practices at all facilities; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

10. Increase employees' awareness of the need to enforce physical-
security safeguards; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

11. Secure and remove construction materials from telecommunications 
and electrical closets that support computer operations; 
Year initially reported: 2009; 
Status of corrective action: Completed. 

Audit area: Improvements to FHFA's information security program: 

12. Develop, document, and implement procedures enforcing separation 
of incompatible duties among personnel; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

13. Finalize, approve, and implement configuration-management policies 
and procedures; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

14. Approve and test continuity of operations and disaster-recovery 
plans; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

15. Develop, document, and implement procedures to monitor access to 
agency financial information by the Bureau of the Public Debt (BPD) 
and Oracle Corporation staff and contractors; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

16. Develop, document, and implement procedures to assess all security 
reviews and plans of action and milestones developed by BPD and Oracle 
Corporation staff and contractors; 
Year initially reported: 2009; 
Status of corrective action: In progress. 

Source: GAO analysis of FHFA data. 

[End of table] 

[End of Enclosure II] 

Enclosure III: Comments from the Federal Housing Finance Agency: 

Federal Housing Finance Agency: 
1700 G Street, N.W. 
Washington, D.C. 20552-0003: 
Telephone: (202) 414-3800: 
Facsimile: (202) 414-3823: 
[hyperlink, http://www.fhfa.gov] 

April 15, 2011: 

Mr. Steven J. Sebastian: 
Director: 
Financial Management and Assurance: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Sebastian: 

Thank you for the opportunity to review and comment on the Management 
Report: Opportunities for Improvement in the Federal Housing Finance 
Agency's Internal Controls and Accounting Procedures. We appreciate 
GAO's efforts in completing this year's review of the Federal Housing 
Finance Agency's internal controls and accounting procedures. I am 
pleased that GAO found FHFA's fiscal years 2010 and 2009 financial 
statements were fairly presented in all material respects and that 
FHFA had effective internal control over financial reporting. 

During the course of the FY 2010 financial statement audit, GAO 
identified opportunities for improvements related to FHFA's internal 
controls and accounting operations. FHFA agrees that GAO's 
recommendations will strengthen our internal controls and accounting 
operations. To that end, FHFA has complied with all of GAO's 
recommendations contained in the Management Report as discussed below. 

Disposal of Capitalized Property and Equipment: 

GAO Recommendation: The Chief Financial Officer should: 

* establish a mechanism to monitor compliance with policies and 
procedures surrounding the proper disposal of capitalized property and 
equipment, and; 

* update the Property Management Policy to include procedures for how 
to properly document approval before disposal of FHFA assets. 

FHFA Response: FHFA agrees with the recommendations. The Deputy Chief 
Operating Officer held a one day meeting with managers from OBFM, 
OTIM, and Facility Operations to discuss property and inventory 
management including proper disposal of property and equipment. 
Property management processes have been outlined and property 
management procedures will be developed. The property management 
procedures will include strengthening controls over the disposal of 
property and equipment. FHFA will be moving to a new building in early 
FY 2012. Property management procedures will be updated to reflect the 
new environment including automation of processes as appropriate. 

Status: 

Held the property and inventory management meeting in January 2011. 

Updated the Property Management Policy and circulated the document for 
the Director's signature. 

Completed property management processes outline in March 2011. 
Property management procedures will be developed this fiscal year. 

Invoice Payment Procedures: 

GAO Audit Recommendation: The Chief Financial Officer should enhance 
FHFA's Invoice and Payments Desktop Procedures to include detailed 
instructions on how to verify the accuracy of invoice amounts prior to 
payment. 

FHFA Response: FHFA agrees that additional guidance needs to be given 
to Invoice Approvers/Contracting Officers Technical Representatives 
(COTR). FHFA and Bureau of the Public Debt (BPD) alerted Invoice 
Approvers/COTRs via written correspondence that an error had been 
identified during the FY 2010 financial audit and instructed them on 
the necessity of careful verification of billed amounts and invoice 
details. FHFA and BPD will provide training sessions covering invoice 
verification and calculation, obligation and expense tracking, and 
invoice approval and rejection process in April 2011. In addition, 
FHFA has created detailed instructions for the review and approval of 
an invoice that will be posted to the intranet and distributed to 
Invoice Approvers/COTRs during the invoice training in April
2011. FHFA has requested that BPD perform a 100% verification of legal 
contract invoices received from October 2010 — March 2011 that are 
similar in nature to those identified by GAO during the audit. 

Status: 

BPD distributed invoice verification email to all Accounting 
Operations Branch employees in September 2010. 

FHFA distributed invoice verification email to all Invoice 
Approvers/COTRs in September 2010. 

Completed Approving an Invoice process document in April 2011. The 
document will be posted to the intranet and distributed to Invoice 
Approvers/COTRs during the April 2011 invoice training. 

Invoice Approver/COTR training will be held in April 2011. 

BPD will complete 100% invoice review of FY 2011 legal invoices during 
May 2011. 

If you have any questions, please contact Michele Horowitz, Deputy 
Chief Financial Officer at (202) 414-3816 or Debbie Olejnik, Manager 
Financial Management Operations and Systems at (202) 414-3817. 

Sincerely, 

Signed by: 

Mark Kinsey: 
Chief Financial Officer: 

[End of Enclosure III] 

Enclosure IV: Details on Audit Scope and Methodology: 

To fulfill our responsibilities as auditor of the financial statements 
of the Federal Housing Finance Agency (FHFA), we did the following: 

* examined, on a test basis, evidence supporting the amounts and 
disclosures in the financial statements; 

* assessed the accounting principles used and significant estimates 
made by FHFA management; 

* evaluated the overall presentation of the financial statements; 

* obtained an understanding of the entity and its operations, 
including its internal control over financial reporting; 

* considered FHFA's process for evaluating and reporting on internal 
control over financial reporting that FHFA is required to perform by 
31 U.S.C. § 3512 (c), (d), commonly known as the Federal Managers' 
Financial Integrity Act of 1982; 

* assessed the risk that a material misstatement exists in the 
financial statements and the risk that a material weakness exists in 
internal control over financial reporting; 

* evaluated the design and operating effectiveness of internal control 
over financial reporting based on the assessed risk; 

* tested relevant internal control over financial reporting; 

* tested compliance with selected provisions of the following laws and 
their related regulations: 31 U.S.C. § 3902 (a), (b), (f) - Interest 
penalties under the Prompt Payment Act; 31 U.S.C. § 3904 - Limitations 
on Discount Payments Under the Prompt Payment Act; 12 U.S.C. § 4515 - 
Personnel; Federal Employees' Retirement System Act of 1986, as 
amended; Social Security Act of 1935, as amended; Federal Employees 
Health Benefits Act of 1959, as amended; 12 U.S.C. § 4516 (g) (4), 
which makes applicable 31 U.S.C. § 3512 (c), Federal Managers' 
Financial Integrity Act of 1982; and Federal Housing Enterprises 
Financial Safety and Soundness Act of 1992, as amended by the Housing 
and Economic Recovery Act of 2008; and: 

* evaluated information security controls based on our Federal 
Information System Controls Audit Manual[Footnote 13] which contains 
guidance for reviewing information systems. 

[End of Enclosure IV] 

Footnotes: 

[1] GAO, Financial Audit: Federal Housing Finance Agency's Fiscal 
Years 2010 and 2009 Financial Statements, [hyperlink, 
http://www.gao.gov/products/GAO-11-151] (Washington, D.C.: Nov. 15, 
2010). 

[2] GAO, Management Report: Opportunities for Improvements in FHFA's 
Internal Controls and Accounting Procedures, [hyperlink, 
http://www.gao.gov/products/GAO-10-587R] (Washington, D.C.: June 3, 
2010). 

[3] GAO, Information Security: Opportunities Exist for the Federal 
Housing Finance Agency to Improve Controls, [hyperlink, 
http://www.gao.gov/products/GAO-10-528] (Washington, D.C.: Apr. 30, 
2010). 

[4] 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. 

[5] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[6] The Transfer of Property Receipt form provides a description of 
the property and the location to which the property is being 
transferred, and certifies that sensitive property containing FHFA 
data has been degaussed in accordance with FHFA policies and 
procedures. 

[7] A catalyst delivers switching solutions for enterprise and service-
provider networks. 

[8] Nonpayroll expense transactions consist of program expenses other 
than payroll, such as rent, travel, consulting and other contracted 
services, postage, printing, and noncapitalized equipment. 

[9] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[10] [hyperlink, http://www.gao.gov/products/GAO-10-587R]. 

[11] [hyperlink, http://www.gao.gov/products/GAO-10-528]. 

[12] Undelivered orders are the value of goods and services ordered 
and obligated that have not been received. This amount includes any 
orders for which advance payment has been made but for which delivery 
or performance has not yet occurred. 

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

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: