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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

Financial Audit: 

American Battle Monuments Commission’s Financial Statements for Fiscal 
Years 2009 and 2008: 

GAO-10-399: 

GAO Highlights: 

Highlights of GAO-10-399, a report to congressional committees. 

Why GAO Did This Study: 

In accordance with 36 U.S.C. 2103, GAO is responsible for conducting 
audits of the agencywide financial statements of the American Battle 
Monuments Commission (the Commission). GAO audited the financial 
statements of the Commission for the fiscal years ended September 30, 
2009, and 2008. 

The audits were done to determine whether, in all material respects, 
(1) the Commission’s financial statements were presented fairly and 
(2) Commission management maintained effective internal control over 
financial reporting. GAO also tested Commission management’s 
compliance with selected laws and regulations. 

Created in 1923, the Commission operates and maintains 24 American 
military cemeteries on foreign soil; 25 federal memorials, monuments, 
and markers; and 7 nonfederal memorials. 

GAO is not making any recommendations in this report, but will be 
reporting separately on our recommendations for strengthening the 
Commission’s controls. 

In commenting on a draft of this report, the Commission concurred with 
its facts and conclusions. Further, the Commission stated it would 
report the Antideficency Act violation and noted that the appointment 
of Commissioners to provide governance resides with the President of 
the United States. 

What GAO Found: 

In GAO’s opinion, the financial statements of the Commission as of 
September 30, 2009, and 2008, and for the fiscal years then ended, are 
presented fairly, in all material respects, in conformity with U.S. 
generally accepted accounting principles. Also, in GAO’s opinion, 
although certain internal controls should be improved, the Commission 
maintained effective internal control over financial reporting as of 
September 30, 2009. In addition, GAO found a reportable instance of 
Commission noncompliance in fiscal year 2009 with selected provisions 
of laws and regulations tested. 

GAO found a significant deficiency in the Commission’s internal 
control over financial reporting as of September 30, 2009. 
Specifically, as of January 20, 2009, all 11 Commissioners, a 
significant component of the Commission’s governance structure, 
resigned and new appointments were not made as of September 30, 2009. 
As a result, there were no Commissioners in place to provide high-
level strategic oversight of Commission internal control over 
financial reporting. GAO also found that a Commission contract for 
temporary employees violated the Antideficiency Act as it contained a 
hold-harmless clause which subjected the Commission to potentially 
unlimited liability. 

For fiscal year 2009, the Commission incurred program costs of $59.0 
million to maintain its cemeteries and federal memorials that were 
financed from appropriated funds. Another $0.8 million of program 
costs incurred by Commission-administered trust funds were financed by 
private contributions for nonroutine repair and maintenance related to 
the World War II Memorial, purchase of grave site flowers, and 
maintenance of nonfederal memorials. 

Figure: The Commission’s WWII Ardennes American Cemetery in Neupre, 
Belgium: 

[Refer to PDF for image: photograph] 

Source: American Battle Monuments Commission. 

[End of figure] 

View [hyperlink, http://www.gao.gov/products/GAO-10-399] or key 
components. For more information, contact Steven J. Sebastian at (202) 
512-3406 or sebastians@gao.gov. 

[End of section] 

Contents: 

Letter: 

Auditor’s Report: 

Opinion on Financial Statements: 

Opinion on Internal Control: 

Compliance With Laws and Regulations: 

Consistency of Other Information: 

Objectives, Scope, and Methodology: 

Commission Comments and Our Evaluation: 

Management’s Discussion and Analysis: 

Financial Statements: 

Consolidating Balance Sheet: 

Consolidating Statement of Net Cost and Changes in Net Position: 

Consolidating Statement of Budgetary Resources: 

Notes to Consolidating and Consolidated Financial Statements: 

Other Information: 

Required Supplementary Information: 

Schedules of Heritage Assets: 

Appendix: 

Appendix I: Comments from the American Battle Monuments Commission: 

[End of section] 

United States Government Accountability Office: 
Washington, D.C. 20548: 

March 1, 2010: 

The Honorable Daniel K. Akaka:
Chairman:
The Honorable Richard Burr:
Ranking Member:
Committee on Veterans' Affairs:
United States Senate: 

The Honorable Bob Filner:
Chairman:
The Honorable Steve Buyer:
Ranking Member:
Committee on Veterans' Affairs:
House of Representatives: 

In accordance with 36 U.S.C. 2103, this report presents the results of 
our audits of the financial statements of the American Battle 
Monuments Commission (the Commission) for the fiscal years ended 
September 30, 2009, and 2008. 

We are sending copies of this report to the Chairmen and Ranking 
Members of the Senate Committee on Appropriations and the House 
Committee on Appropriations. We are also sending copies to the 
Director of the Office of Management and Budget, the Secretary of the 
Commission, and other interested parties. This report also will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

Should you or your staffs have any questions concerning this report, 
please contact me at (202) 512-3406 or at sebastians@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Key contributors to this 
engagement were Roger R. Stoltz, Patricia A. Summers, Cara H. Larson, 
West E. Coile, Francis L. Dymond, Jason S. Kirwan, Melanie B. Swift, 
Heather Moreland, and Ryan M. Heiling. 

Signed by: 

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

[End of letter] 

United States Government Accountability Office: 
Washington, D.C. 20548: 

To the Secretary of the American Battle Monuments Commission: 

In accordance with 36 U.S.C. 2103, we are responsible for conducting 
audits of the agencywide financial statements of the American Battle 
Monuments Commission (the Commission). In our audits of the 
Commission's financial statements for fiscal years 2009 and 2008, we 
found: 

* the consolidating financial statements as of and for the fiscal year 
ended September 30, 2009, and comparative consolidated totals as of 
and for the fiscal year ended September 30, 2008, are presented 
fairly, in all material respects, in conformity with U.S. generally 
accepted accounting principles; 

* although certain controls should be improved, the Commission had 
effective internal control over financial reporting as of September 
30, 2009; and: 

* the Commission did not comply with one of the provisions of laws and 
regulations we tested. 

The following sections discuss in more detail (1) our basis for these 
conclusions; (2) our conclusions on Management's Discussion and 
Analysis and other supplementary information; (3) our audit 
objectives, scope, and methodology; and (4) Commission comments. 

Opinion On Financial Statements: 

The Commission's consolidating balance sheet as of September 30, 2009, 
consolidating statement of net cost and changes in net position, and 
consolidating statement of budgetary resources, with accompanying 
notes for the fiscal year then ended, and comparative consolidated 
totals as of and for the fiscal year ended September 30, 2008, are 
presented fairly, in all material respects, in conformity with U.S. 
generally accepted accounting principles. 

Opinion On Internal Control: 

Although certain controls should be improved as discussed below, the 
Commission maintained, in all material respects, effective internal 
control over financial reporting as of September 30, 2009. Commission 
internal control provided reasonable assurance that misstatements, 
losses, or noncompliance material in relation to the consolidating 
financial statements would be prevented or detected and corrected on a 
timely basis. Our opinion is based upon criteria established under 31 
U.S.C. 3512 (c), (d) commonly known as the Federal Managers' Financial 
Integrity Act of 1982 (FMFIA). 

Significant Deficiency: 

As of September 30, 2009, the Commission had a significant deficiency 
in its governance structure because all Commissioner positions were 
vacant. Under the Commission's enabling legislation, up to 11 
Commissioners and the Secretary are appointed by the President of the 
United States. The Commissioners are charged with the execution of the 
Commission's mission, but may delegate any of its authorities to its 
Chairman, the Secretary, or to other officials in charge of Commission 
offices. Historically, most of these officials were senior (active or 
retired) military officers who provided top-level strategic direction 
to the program, budget, and financial operations of the Commission. 
Consistent with U.S. generally accepted government auditing standards, 
the Commissioners, the Secretary, and other designated officials 
collectively function as the Commission's governance structure. 
[Footnote 1] 

On or about January 20, 2009, all 11 Commissioners and the Secretary 
resigned. While the President appointed a new Commission Secretary on 
June 3, 2009, Commissioner appointments had not been made as of 
September 30, 2009. Therefore, Commissioners were not available to 
provide high-level strategic oversight of Commission internal control 
over financial reporting for the last 8 months of fiscal year 2009. 
Further, we did not find any evidence of the Commissioners' express 
delegation of authority and assignment of responsibilities to the 
Secretary. However, the new Secretary directed efforts to maintain, in 
all material respects, effective internal control over financial 
reporting. 

During fiscal year 2009, the Commission engaged an outside contractor 
to assess whether the Commission's internal control process and 
procedures were effective and operating to achieve their intended 
objectives pursuant to FMFIA and its implementing guidance contained 
in Office of Management and Budget (OMB) Circular A-123, Management's 
Responsibility for Internal Control. According to the Commission's 
2009 FMFIA report, the contractor's efforts have indicated that the 
Commission's management control program appears to be effective in 
meeting management's expectations for compliance with federal 
requirements. 

We tested the Commission's internal control to the extent necessary to 
express an opinion on the internal control over financial reporting. 
Our work indicated that the Commission's internal control as of 
September 30, 2009, provided reasonable assurance that misstatements, 
losses, or noncompliance material to the Commission's consolidating 
financial statements would be prevented, or detected and corrected. 
Nevertheless, we consider the absence of Commissioners and the lack of 
any delegations of authority and assignment of responsibilities to the 
Secretary as of September 30, 2009, to be a significant deficiency 
under U.S. generally accepted government auditing standards.[Footnote 
2] 

We identified other less significant matters concerning the 
Commission's internal control that we will report separately. 

Compliance With Laws And Regulations: 

Our tests of the Commission's compliance with selected provisions of 
laws and regulations for fiscal year 2009 disclosed one instance of 
noncompliance that is reportable under U.S. generally accepted 
government auditing standards. We determined that a Commission 
contract with a commercial employment services firm to provide 
temporary employees to the Commission violated the Antideficiency Act 
because it contained an open-ended hold-harmless clause which 
subjected the Commission to potentially unlimited liability.[Footnote 
3] While the contractor terminated the contract before September 30, 
2009, Commission officials agreed with our conclusion that the hold-
harmless clause was an Antideficiency Act violation.[Footnote 4] 

Our tests for compliance with laws and regulations disclosed no other 
instances of noncompliance that would be reportable under U.S. 
generally accepted government auditing standards. However, the 
objective of our audit was not to provide an opinion on overall 
compliance with laws and regulations. Accordingly, we do not express 
such an opinion. 

Consistency Of Other Information: 

The Commission's Management Discussion and Analysis and other 
information related to heritage assets presented in the Commission's 
financial report contain a wide range of data, some of which are not 
directly related to the financial statements. We do not express an 
opinion on this information. However, we compared this information for 
consistency with the financial statements and discussed the methods of 
measurement and presentation with officials of the Commission. On the 
basis of this limited work, we found no material inconsistencies with 
the financial statements, U.S. generally accepted accounting 
principles, and OMB Circular No. A-136, Financial Reporting 
Requirements. 

Objectives, Scope, and Methodology: 

Commission management is responsible for (1) preparing the financial 
statements in conformity with U.S. generally accepted accounting 
principles, (2) establishing and maintaining effective internal 
control over financial reporting and evaluating its effectiveness, and 
(3) complying with applicable laws and regulations. Commission 
management evaluated the effectiveness of its internal control over 
financial reporting as of September 30, 2009, based upon the criteria 
established under FMFIA. Commission management provided an assertion 
concerning the effectiveness of its internal control over financial 
reporting (see appendix I). 

We are responsible for planning and performing the audit to obtain 
reasonable assurance and provide our opinion about whether (1) the 
Commission's financial statements are presented fairly, in all 
material respects, in conformity with U.S. generally accepted 
accounting principles, and (2) Commission management maintained, in 
all material respects, effective internal control over financial 
reporting as of September 30, 2009. We are also responsible for (1) 
testing compliance with selected provisions of laws and regulations 
that have a direct and material effect on the financial statements, 
and (2) performing limited procedures with respect to certain other 
information accompanying the financial statements. In order to fulfill 
these responsibilities, we: 

* examined, on a test basis, evidence supporting the amounts and 
disclosures in the financial statements. This included selecting 
statistical samples of payroll and nonpayroll expenditures primarily 
to determine the validity of activities reported in the Commission's 
financial statements. We projected any errors in dollar amounts to the 
population of transactions from which they were selected. In testing 
some of these samples, certain attributes were identified that 
indicated deficiencies in the design or operation of internal control. 
These attributes, where applicable, were statistically projected to 
the appropriate populations; 

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

* evaluated the overall presentation of the financial statements; 

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

* considered the Commission's process for evaluating and reporting on 
internal control over financial reporting based on criteria 
established under FMFIA; 

* assessed the risk of (1) material misstatements in the financial 
statements, and (2) material weaknesses in internal control over 
financial reporting; 

* tested relevant internal control over financial reporting; 

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

* tested compliance with selected provisions of the following laws and 
regulations: 

- the Commission's enabling legislation codified in 36 U.S.C. Chapter 
21, 

- public laws applicable to the World War II Memorial Fund, 

- Buffalo Soldiers Commemoration Act of 2005, 

- Consolidated Security, Disaster Assistance, and Continuing 
Appropriations Act, 2009, 

- Antideficiency Act, 

- Pay and Allowance System for Civilian Employees, and: 

- Prompt Payment Act. 

An entity's internal control over financial reporting is a process 
affected by those charged with governance, management, and other 
personnel, the objectives of which are to provide reasonable assurance 
that (1) transactions are properly recorded, processed, and summarized 
to permit the preparation of financial statements in accordance with 
U.S. generally accepted accounting principles, and assets are 
safeguarded against loss from unauthorized acquisition, use, or 
disposition; and (2) transactions are executed in accordance with the 
laws governing the use of budget authority and other laws and 
regulations that could have a direct and material effect on the 
financial statements. 

We did not evaluate all internal control relevant to operating 
objectives as broadly defined by FMFIA, such as controls relevant to 
preparing statistical reports and ensuring efficient operations. We 
limited our internal control testing to testing controls over 
financial reporting. Because of inherent limitations in internal 
control, internal control may not prevent or detect and correct 
misstatements due to error or fraud, losses, or noncompliance. We also 
caution that projecting any evaluation of effectiveness to future 
periods is subject to the risk that controls may become inadequate 
because of changes in conditions, or that the degree of compliance 
with policies or procedures may deteriorate. 

We did not test compliance with all laws and regulations applicable to 
the Commission. We limited our tests of compliance to those laws and 
regulations that have a direct and material effect on the financial 
statements for the fiscal year ended September 30, 2009. We caution 
that noncompliance may occur and not be detected by these tests and 
that such testing may not be sufficient for other purposes. 

We performed our audit in accordance with U.S. generally accepted 
government auditing standards. We believe our audit provides a 
reasonable basis for our opinions and other conclusions. 

Commission Comments And Our Evaluation: 

In commenting on a draft of this report, Commission management 
concurred with its facts and conclusions. The Commission official also 
commented that the Antideficiency Act violation was mitigated due to 
the termination of the contract prior to September 30, 2009, and no 
funds were obligated in excess of appropriations. However, in 
accordance with the Act and guidance issued by OMB, the Commission 
also stated it would report the violation and relevant facts to the 
Congress and the President of the United States, with a copy to the 
Comptroller General. With regard to the significant deficiency related 
to governance, the Commission noted that responsibility for appointing 
commissioners resides with the President of the United States. 

We note that although no funds were expended to pay any claims by the 
contractor under the hold-harmless clause, the clause itself is a 
binding obligation of the Commission to pay amounts that could exceed 
its available appropriations if certain conditions outside the control 
of the Commission were to materialize. Under Supreme Court and 
Comptroller General precedent, such obligations violate the 
Antideficiency Act in the absence of specific statutory authority. 

Sincerely yours, 

Signed by: 

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

February 17, 2010: 

[End of section] 

Management's Discussion And Analysis: 

American Battle Monuments Commission: 
Annual Financial Report: 
Management's Discussion And Analysis (MDA): 
For The Fiscal Year Ended September 30, 2009: 

Mission: 

The American Battle Monuments Commission (the Commission) — guardian 
of America's overseas commemorative cemeteries and memorials — honors 
the service, achievements and sacrifice of the United States armed 
forces. Since 1923, the Commission has executed this mission by (1) 
commemorating the achievements and sacrifices of America's armed 
forces through the erection and maintenance of suitable memorial 
shrines in the U.S. when authorized by Congress and where they have 
served overseas since April 6, 1917; (2) designing, constructing, 
operating, and maintaining permanent American military burial grounds 
in foreign countries; and (3) controlling the design and construction 
on foreign soil of U.S. military memorials, monuments, and markers by 
other U.S. citizens and organizations, both public and private, and 
encouraging their maintenance. The Commission's fiscal year 2009 
appropriation supported its continued commitment to the worldwide 
responsibilities that flow from this mission. 

In performance of its mission, the Commission administers, operates, 
and maintains 24 permanent American military cemeteries; 25 federal 
memorials, monuments, and markers; and seven nonfederal memorials. 
Three memorials are located in the United States; the remaining 
memorials and all of the Commission's cemeteries are located in 14 
foreign countries, the U.S. Commonwealth of the Northern Mariana 
Islands, and the British dependency of Gibraltar. These cemeteries and 
memorials are among the most beautiful and meticulously maintained 
shrines in the world. The Commission's World War I, World War II, and 
Mexico City cemeteries are closed to future burials except for the 
remains of U.S. war dead discovered in World War I and II battle areas. 

In addition to grave sites, the World War I and II cemeteries, 
together with three memorials on U.S. soil, commemorate by name on 
Tablets of the Missing those U.S. service members who were missing in 
action or lost or buried at sea during the First and Second World Wars 
and the Korean and Vietnam Wars. 

The Commission also administers trust funds to (1) build memorials 
authorized by Congress, but financed primarily from private 
contributions, commemorative coin proceeds, and investment earnings; 
(2) decorate grave sites with flowers from private contributions; and 
(3) maintain and repair nonfederal war memorials with private 
contributions. 

During fiscal year 2009, the Commission continued to ensure that its 
commemorative cemeteries and memorials remain fitting shrines to those 
who have served our nation in uniform since America's entry into World 
War I. 

The Commission's mission statement: 

The American Battle Monuments Commission—guardian of America's
overseas commemorative cemeteries and memorials—honors the service,
achievements, and sacrifice of United States Armed Forces. 

Organizational Structure: 

The Commission's organizational structure for fiscal year 2009 is 
shown in figure 1. 

Figure 1: The Commission's Organizational Structure: 

[Refer to PDF for image: organization structure] 

Top level: 
Board of Commissioners (Chairman and 10 Commissioners appointed by the 
President): 

Second level, reporting to the Board of Commissioners: 
Commission Secretary (appointed by the President): 

Third level, reporting to the Commission Secretary: 
Executive Director: 
* Headquarters Staff: 
- Personnel & Administration; 
- Finance; 
- Engineering & Maintenance; 
- Public Affairs. 

Fourth level, reporting to the Executive Director: 
Regional Director (Mediterranean) (4 Cemeteries); 
Regional Director (European) (17 Cemeteries); 
Independent Cemeteries (3 Cemeteries). 

Authorized Strength (FTE): 
US-General Service: 72; 
Foreign Service Nationals: 337; 
Total: 409. 

[End of figure] 

The Commission's policy-making body consists of an 11-member Board of 
Commissioners appointed by the President of the United States for an 
indefinite term and whose members serve without pay. The commissioners 
establish policy and ensure proper staff functioning in carrying out 
the mission of the Commission. During inspection visits to Commission 
cemeteries, they observe, inquire about, comment upon, and make 
recommendations on any and all aspects of Commission operations. The 
new Administration had not appointed a Board of Commissioners by the 
close of the fiscal year. The Commission's daily operations are 
directed by an Executive Level Secretary, who is appointed by the 
President and assisted by an Executive Director, a member of the 
Senior Executive Service. 

The Commission's headquarters office is in Arlington, Virginia and 
regional offices are located in Garches, France, just outside Paris, 
and in Rome, Italy. For fiscal year 2009, the Commission had a total 
of 409 full-time equivalent (FTE) positions. U.S. citizens constituted 
72 members of the staff, while the remaining 337 were foreign service 
nationals employed at the Commission's regional offices and at the 
cemeteries in the countries where the Commission operates. 

Operations Management: 

Operations management activities in fiscal year 2009 focused on 
funding salaries and benefits, service fees, scheduled maintenance and 
repairs, supplies, materials, spare parts, replacement of 
uneconomically repairable equipment, and capital improvements. 

For fiscal year 2009, the Commission received $59,470,000 from 
appropriations in its Salaries and Expenses account. Additionally, the 
Commission received $500,000 from the United States Air Force to 
conduct an engineering study on the restoration of the Lafayette 
Escadrille Memorial in Marnes-La-Coquette, France. The Commission's 
Foreign Currency Fluctuation Account appropriation for fiscal year 
2009 contained "such sums as may be necessary" language. For fiscal 
year 2009, the Commission estimated $17,100,000 be used to offset 
currency exchange losses. Figure 2 shows how the Commission obligated 
funding from its Salaries and Expenses account, by object class. 

Figure 2: Fiscal Year 2009 Obligations by Object Class: 

[Refer to PDF for image: pie-chart] 

Compensation & Benefits: 49%; 
Contracts, Services, & Capital Improvements: 31%; 
Rent & Utilities: 7%; 
Equipment: 5%; 
Printing & Supplies: 5%; 
Travel & Transportation: 3%. 

[End of figure] 

The Commission has received funding for engineering, maintenance and 
horticulture programs that make the Commission's facilities among the 
most beautiful memorials in the world. These shrines to America's war 
dead require a formidable annual program of maintenance and repair of 
facilities, equipment, and grounds. 

The Commission prioritizes the use of its engineering, maintenance and 
horticulture funds carefully to ensure the most effective and 
efficient utilization of its available resources. This care includes 
upkeep of more than 131,000 graves and headstones and 73 memorial 
structures (within and external to the cemeteries) on approximately 
1,650 acres of land. Additionally, the Commission maintains 65 visitor 
facilities and quarters for assigned personnel; 67 miles of roads and 
paths; 911 acres of flowering plants, fine lawns, and meadows; 3 
million square feet of shrubs and hedges; and 11,000 ornamental trees. 

Care and maintenance of these resources requires exceptionally 
intensive labor at the Commission's cemeteries and memorials. 
Compensation and benefits consumed approximately 49 percent of the 
Commission's fiscal year 2009 spending while the remaining 51 percent 
supported engineering, maintenance, horticulture, logistics, services, 
supplies and other administrative costs critical to its operations.
High Priority Performance Goals and Results
Summarized below are the Commission's performance goals and results.
Goal 1: To develop, operate, maintain, and improve Commission 
facilities as the world's best commemorative sites. 

Objectives for Goal 1: 

* Develop, implement, and sustain best business practices for 
commemorative operations. 

* Sustain standardized processes for cemetery management and 
maintenance. 

* Strengthen management of engineering, horticulture, logistics, and 
interpretation programs. 

Strategy for Achieving Goal 1: 

The Commission takes a systematic look at its aging facilities. It 
addresses areas that will reduce the growth of operational and routine 
maintenance costs and promote more effective long-term planning, 
operations, and resource management. 

Since fiscal year 2000, the Commission has successfully worked to 
resolve deficiencies noted during in-depth technical surveys conducted 
by professional engineering firms that applied current industry 
standards, regulations, and technological advances in making their 
assessment. In fiscal year 2009, the Commission worked to implement 
standardized processes for cemetery management and maintenance and to 
prioritize that work based on a systematic process of review and 
analysis. 

Selected Performance Results toward Achieving Goal 1: 

* The following are examples of the engineering, maintenance and 
horticulture projects executed in fiscal year 2009: 

- storm drainage and road repairs at the Meuse-Argonne American 
Cemetery; 

- service area renovation at the Sicily-Rome American Cemetery 

- roof and deep well replacement at the Manila American Cemetery; 

- irrigation system replacement at the Cambridge American Cemetery. 

* The Commission continued successful implementation of the equipment 
template program which has shown great promise in regularizing 
equipment purchase and use across the cemeteries. 

* With the additional FTE approved in fiscal year 2009, the Commission 
added an Engineering Technician to complement the overseas engineering 
workforce and to strengthen management of engineering projects. 

* The Commission continued to standardize processes for cemetery 
management and maintenance with periodic reviews which identify and 
prioritize engineering, maintenance and horticulture requirements. 

Goal 2: To value and invest in each employee. 

Objectives for Goal 2: 

* Recruit, develop, and retain a world-class workforce. 

* Recognize and award superior performance. 

* Create an environment in which employees feel that their needs are 
being met. 

* Develop a skilled and dedicated workforce by encouraging learning 
throughout the organization. 

* Ensure that employees have a stake in and can relate their jobs to 
the vision. 

* Ensure that employees are energized and "feel good" about working at 
the Commission. 

* Communicate Commission programs and priorities to employees. 

Strategy for Achieving Goal 2: 

Employee assistance programs play a critical role in recruiting and 
retaining a world-class workforce. The Commission provides programs 
and assistance that help employees and prospective employees manage 
their personal and familial responsibilities concurrently with their 
jobs. This also enables employees to feel that their personal needs 
are being met. 

Selected Performance Results toward Achieving Goal 2: 

* In coordination with Federal Occupational Health under the 
Department of Health and Human Services, the Commission has continued 
its formal Employee Assistance Program. 

* The Commission held a comprehensive strategic planning conference 
attended by a wide-range of key stakeholders. Through this 
undertaking, emphasis was placed on each employee's quality of life, 
both professionally and personally. 

* A telework policy was drafted for agency head approval to supplement 
the previous fiscal year's Alternative Work Schedule Pilot Program. 

Goal 3: To have the Commission's commemorative sites recognized 
worldwide as inspirational and educational visitor destinations. 

Objectives for Goal 3: 

* Increase public awareness and understanding of the Commission's 
commemorative mission. 

* Increase the number of visitors to Commission cemeteries and 
memorials. 

* Satisfy constituents' needs through timely distribution of 
information and products. 

Strategy for Achieving Goal 3: 

The Commission honors the service and sacrifice of the men and women 
memorialized in Commission cemeteries by operating and maintaining 
uniquely splendid commemorative cemeteries and memorials. But to truly 
honor their memory the Commission also must tell their stories. To 
achieve this objective, the Commission initiated an interpretive 
program in fiscal year 2008 to adapt the storytelling techniques and 
visitor programs used so successfully in the Normandy Visitor Center 
to the existing visitor buildings at the Pointe du Hoc Ranger Monument 
and its 23 other cemeteries. Interpretive program site surveys were 
completed for Cambridge, Manila, Oise-Aisne, Netherlands and Sicily-
Rome cemeteries during this fiscal year, and exhibit design was begun 
for Pointe du Hoc. Cambridge, Oise-Aisne and Sicily-Rome cemeteries 
were selected as the next cemetery sites for interpretive program 
development, with the objective of completing work at Cambridge in 
time for the 2012 Summer Olympics in London. 

The Commission continued its efforts to increase public awareness of 
its commemorative mission and to encourage more U.S. and foreign 
citizens to visit its cemeteries and memorials worldwide. 
Concurrently, the Commission began a redesign of its Web site and war 
dead database to expand the amount of information provided to the 
public through the site and to make it more attractive and visitor 
friendly. 

Selected Performance Results toward Achieving Goal 3: 

* In support of next of kin and other customers who use its services, 
the Commission provided burial and memorialization site information; 
letters authorizing no-fee passports for members of the immediate 
family traveling overseas primarily to visit a Commission cemetery; in-
country travel information; and, upon arrival at the cemetery, escort 
to the appropriate grave or memorialization site. Requesters were 
provided a photograph taken of the appropriate headstone or section of 
the Tablet of the Missing, which was mounted on a color lithograph of 
the cemetery or memorial where a service member is buried or 
commemorated by name. The Commission also purchased floral decorations 
with donor funds and each donor was given a photograph of the 
headstone or Tablet of the Missing with the decoration in place. 

* In addition to responding to inquiries by friends and relatives of 
the war dead interred or memorialized at its sites, the Commission 
also provided information to the executive branch, Members of 
Congress, government agencies, historians, and other interested 
individuals. The Commission provided cemetery lithographs, photos, and 
other information throughout the year. 

* The Commission's Web site at [hyperlink, http://www.abmc.gov] 
provided visitors with information on the Commission and its 
commemorative sites, as well as information on U.S. war dead from the 
Korean and Vietnam Wars and those interred or commemorated at the 
Commission's World War I and World War II cemeteries and memorials. 
The quality of historical information on the Commission Web site 
continued to improve when a campaign interactive program on the 
"Battle for Pointe du Hoc," recognized as a Web site of the week by 
Communication Arts Magazine, was added to the site. An effort to merge 
multiple Commission war dead databases into a single, integrated file 
was nearing completion as the fiscal year ended and will be posted 
when the new Web site design is completed in fiscal year 2010. 

* Throughout the year, the Commission hosted a variety of special 
events and commemorations, including ceremonies on Veterans Day in 
November, Memorial Day in May, and an international commemoration of 
the 65th Anniversary of the D-Day landings in June. The D-Day ceremony 
at Normandy American Cemetery was attended by the presidents of the 
United States and France, the prime ministers of England and Canada, 
and England's Prince Charles. In addition, throughout the year 
military units, veterans groups, and local citizens and organizations 
paid tribute to those who died while liberating their regions, whether 
through organized ceremonies or individual visits to graves "adopted" 
by local families. 

* Through a variety of methods, the Commission continued to work 
toward achieving its strategic goal of having its commemorative sites 
recognized for their educational and inspirational qualities. A PBS 
documentary on the Commission that premiered on Memorial Day in May 
2009 and the 65th anniversary of D-Day commemoration at Normandy 
cemetery combined to bring significant national and international 
attention to the Commission mission. The one-hour documentary—Hallowed 
Grounds—is expected to air on PBS outlets across the country several 
times a year over for the next decade. 

* The American Veterans of WWII, Korea, and Vietnam (AMVETS) and the 
Robert R. McCormick Tribune Foundation presented the 20th carillon the 
organizations have donated to the Commission over the years. During 
the May 2009 Memorial Day ceremony, a carillon was dedicated at Epinal 
American Cemetery in France. AMVETS installed the first carillon in 
our Manila cemetery in 1985 and subsequently formed a partnership with 
the foundation. 

* To further satisfy constituent needs for information, the Commission 
produced newly designed visitor brochures in multiple languages for 
Cambridge, Manila, Netherlands, Oise-Aisne and Sicily-Rome cemeteries, 
the first increment of a three-year effort to produce new brochures 
for all Commission cemeteries. 

Goal 4: To make the Commission's business and resource management the 
best in government. 

Objectives for Goal 4: 

* Fully resource the Commission's mission, vision, and standards. 

* Improve internal controls. 

* Leverage cutting-edge business technologies and practices. 

Strategy for Achieving Goal 4: 

The Commission recognizes that improved financial performance depends 
on putting useful and timely information in the hands of its managers 
so they can make timely and informed decisions. The fiscal year 2009 
budget not only supported the Commission's daily accounting operations 
and proper internal controls, but allowed it to identify, develop, and 
employ additional management needs and reports to provide the best 
financial information available. Central to achieving the Commission's 
business and resources process improvement goal are mechanisms that 
aid managers at all levels of the organization in monitoring and 
evaluating the wide variety of systems and programs inherent in its 
operations. 

The Commission must maximize the return on all resources provided by 
the Administration and the Congress. Its fixed costs continue to 
consume a greater percentage of its total salaries and expenses 
appropriation. 

Selected Performance Results toward Achieving Goal 4: 

* The Commission's allocation processes and procedures annually fully 
fund its mandatory and operational requirements in order to achieve 
its mission requirements. 

* During fiscal year 2009, the Commission initiated an effort to 
update the five year strategic plan, including the development of 
performance measures and metrics. 

* A baseline internal control review and risk assessment was begun in 
fiscal year 2009 to examine the Commission's internal control 
mechanisms and business processes. 

* The Commission continues to receive "clean opinions" from its annual 
audit by the Government Accountability Office, with no material 
weaknesses noted. 

* The Commission continues to report that its internal control 
policies and procedures provide reasonable assurance that it complies 
with the provisions of 31 U.S.C. 3512 (c), (d) — Federal Managers' 
Financial Integrity Act (FMFIA). 

Financial Statements and Limitations: 

Since fiscal year 1997, the Commission has been required to produce 
financial statements and the Comptroller General of the United States 
has been required to independently audit these statements. The 
Commission earned unqualified opinions, each year, on its financial 
statements from the Government Accountability Office. 

The financial statements have been prepared to report the financial 
position and results of operations of the Commission, pursuant to the 
requirements of 31 U.S.C. 3515 (b). While the statements have been 
prepared from the books and records of the Commission in accordance 
with generally accepted accounting principles for federal entities and 
the formats prescribed by the Office of Management and Budget the 
statements are in addition to the financial reports used to monitor 
and control budgetary resources which are prepared from the same books 
and records. The statements are for a component of the U.S. 
Government, a sovereign entity. 

Management Integrity: Systems, Controls, Legal Compliance: 

The Commission is cognizant of the importance of, and need for, 
management accountability and responsibility as the basis for quality 
and timeliness of program performance, mission accomplishment, 
productivity, cost-effectiveness, and compliance with applicable laws. 
It has taken management actions to ensure that the annual evaluation 
of these controls is performed in a conscientious and thorough manner 
according to Office of Management and Budget regulations and 
guidelines and in compliance with 31 U.S.C. 3512 (c), (d), commonly 
known as FMFIA. The Commission's evaluation of its system of internal 
management practices and controls during fiscal year 2009 revealed no 
material weaknesses. The objectives of the Commission's internal 
management control policies and procedures are to provide reasonable 
assurance that: 

* obligations and costs are in compliance with applicable law; 

* funds, property, and other assets are safeguarded against waste, 
loss, unauthorized use, and misappropriation; 

* revenue and expenditures applicable to agency operations are 
promptly recorded and accounted for; and; 

* programs are efficiently and effectively carried out in accordance 
with applicable laws and management policy. 

Based on its evaluation, the Commission concluded that there is 
reasonable assurance that it complies with the provisions of FMFIA. 
The reasonable assurance concept recognizes that the cost of internal 
controls should not exceed the benefits expected to be derived and 
that the benefits reduce the risk of failing to achieve stated 
objectives. 

Future Effects, Risks, and Uncertainties: 

Changes in the rate of exchange for foreign currencies have a 
significant impact on the Commission's day-to-day operations. In order 
to insulate the Commission's annual appropriation against major 
changes in its purchasing power, Congress enacted legislation in 1988 
(codified in 36 U.S.C. 2109) to establish a foreign currency 
fluctuation account in the U.S. Treasury. However, since the summer of 
2006, the U.S. dollar has fallen precipitously against the euro. The 
Commission has been closely monitoring this because its budget is 
disproportionately affected by foreign currency fluctuation. As a 
hedge against currency fluctuation, the Commission proposed a change 
that would affect the appropriations language for the Foreign Currency 
Fluctuation Account. In seeking "such sums as may be necessary" 
language, the Commission would preserve its purchasing power against a 
suddenly falling U.S. dollar against the euro. The Administration and 
Congress enacted "such sums as may be necessary" language for the 
Commission's fiscal year 2009 Foreign Currency Fluctuation Account 
appropriation. With this language the Commission will continue to 
estimate and report its FCFA requirements as it has in the past. 
However, when a need arises where the amount forecast by the 
Commission for this account is insufficient, the Commission will 
submit an adjusted estimate to the Office of Management and Budget and 
to the Congress. 

Overall, by maintaining close scrutiny of the Commission's obligation 
status, as well as monitoring and distributing the Foreign Currency 
Fluctuation Account balance, the Commission reduces its overall future 
financial risk to continued operations. 

[End of section] 

Financial Statements: 

Consolidating Balance Sheet: 

American Battle Monuments Commission: 
Consolidating Balance Sheet: 
As of September 30, 2009: 
(With Comparative Consolidated Total as of September 30, 2008): 

Assets: 

Intragovemmental: 

Fund balance with Treasury (note 2); 
General Fund, Cemeteries and Memorials: $44,278,552; 
Trust Funds, WWII and Other Trust Funds: $3,101,084; 
Total Funds, Total 2009: $47,379,636; 
Total Funds, Total 2008: $31,364,215. 

Treasury investments, net (note 3); 
General Fund, Cemeteries and Memorials: [Empty]; 
Trust Funds, WWII and Other Trust Funds: $9,380,713; 
Total Funds, Total 2009: $9,380,713; 
Total Funds, Total 2008: $5,818,787. 

Total Intragovemmental: 
General Fund, Cemeteries and Memorials: $44,278,552; 
Trust Funds, WWII and Other Trust Funds: $12,481,797; 
Total Funds, Total 2009: $56,760,349; 
Total Funds, Total 2008: $37,183,002. 

Cash and foreign accounts (note 4): 
General Fund, Cemeteries and Memorials: $228,671; 	
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $228,671; 
Total Funds, Total 2008: $91,678. 

Contributions receivable, net (note 5): 
General Fund, Cemeteries and Memorials: $0; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $0; 
Total Funds, Total 2008: $0. 

General property and equipment, net (note 6): 
General Fund, Cemeteries and Memorials: $2,883,378; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $2,883,378; 
Total Funds, Total 2008: $2,355,139. 

Heritage property (note 6): 
General Fund, Cemeteries and Memorials: $0; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $0; 
Total Funds, Total 2008: $0; 

Total Assets: 
General Fund, Cemeteries and Memorials: $47,390,601; 
Trust Funds, WWII and Other Trust Funds: $12,481,797; 
Total Funds, Total 2009: $59,872,398; 
Total Funds, Total 2008: $39,629,819; 

Liabilities: 

Intragovemmental: 

Accounts payable: 
General Fund, Cemeteries and Memorials: $158,804; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $158,804; 
Total Funds, Total 2008: $192,791. 

Accrued salaries and benefits: 
General Fund, Cemeteries and Memorials: $440,871; 
Trust Funds, WWII and Other Trust Funds: $192; 
Total Funds, Total 2009: $441,063; 
Total Funds, Total 2008: $354,182. 

Total Intragovemmental: 
General Fund, Cemeteries and Memorials: $599,675; 
Trust Funds, WWII and Other Trust Funds: $192; 
Total Funds, Total 2009: $599,867; 
Total Funds, Total 2008: $546,973. 

Accounts payable: 
General Fund, Cemeteries and Memorials: $2,995,268; 
Trust Funds, WWII and Other Trust Funds: $8,486; 
Total Funds, Total 2009: $3,003,754; 
Total Funds, Total 2008: $2,286,551. 

Other liabilities (note 7): 
General Fund, Cemeteries and Memorials: $4,511,316; 
Trust Funds, WWII and Other Trust Funds: $5,096; 
Total Funds, Total 2009: $4,516,412; 
Total Funds, Total 2008: $3,905,872. 

Total Liabilities: 
General Fund, Cemeteries and Memorials: $8,106,259; 
Trust Funds, WWII and Other Trust Funds: $13,774; 
Total Funds, Total 2009: $8,120,033; 
Total Funds, Total 2008: $6,739,396. 

Commitments and contingencies (note 8): 

Net Position (note 9): 

Unexpended appropriations: 
General Fund, Cemeteries and Memorials: $39,267,566; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $39,267,566; 
Total Funds, Total 2008: $20,610,467. 

Cumulative Results of Operations (deficit): 
General Fund, Cemeteries and Memorials: $16,776; 
Trust Funds, WWII and Other Trust Funds: $12,468,023; 
Total Funds, Total 2009: $12,484,799; 
Total Funds, Total 2008: $12,279,956. 

Total Net Position: 
General Fund, Cemeteries and Memorials: $39,284,342; 
Trust Funds, WWII and Other Trust Funds: $12,468,023; 
Total Funds, Total 2009: $51,752,365; 
Total Funds, Total 2008: $32,890,423. 

Total Liabilities and Net Position: 
General Fund, Cemeteries and Memorials: $47,390,601; 
Trust Funds, WWII and Other Trust Funds: $12,481,797; 
Total Funds, Total 2009: $59,872,398; 
Total Funds, Total 2008: $39,629,819. 

The accompanying notes are an integral part of these statements. 

[End of Consolidating Balance Sheet] 

Consolidating Statement of Net Cost and Changes in Net Position: 

American Battle Monuments Commission: 
Consolidating Statement Of Net Cost And Changes In Net Position: 
For the Year Ended September 30, 2009: 
(With Comparative Consolidated Total for the Year Ended September 30, 
2008): 

Program Costs: 
				
Intragovemmental program costs: 

Operations and maintenance: 
General Fund, Cemeteries and Memorials: $8,895,199; 
Trust Funds, WWII and Other Trust Funds: $456,046; 
Total Funds, Total 2009: $9,351,245; 
Total Funds, Total 2008: $9,693,311. 

Program costs with the public: 

Operations and maintenance: 
General Fund, Cemeteries and Memorials: $38,669,228; 
Trust Funds, WWII and Other Trust Funds: $371,027; 
Total Funds, Total 2009: $39,040,255; 
Total Funds, Total 2008: $27,661,028; 

Property and equipment (note 6): 
General Fund, Cemeteries and Memorials: $2,887,482; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $2,887,482; 
Total Funds, Total 2008: $4,694,825. 

Foreign currency losses, net: 
General Fund, Cemeteries and Memorials: $8,565,315; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $8,565,315; 
Total Funds, Total 2008: $11,394,894. 

Net Cost of Operations: 
General Fund, Cemeteries and Memorials: $59,017,224; 
Trust Funds, WWII and Other Trust Funds: $827,073; 
Total Funds, Total 2009: $59,844,297; 
Total Funds, Total 2008: $53,444,058. 

Changes In Net Position: 

Cumulative Results (Deficit) - Start of Year: 
General Fund, Cemeteries and Memorials: ($434,324); 
Trust Funds, WWII and Other Trust Funds: $12,714,280; 
Total Funds, Total 2009: $12,279,956; 
Total Funds, Total 2008: $11,280,483. 

Budgetary Financing Sources: Appropriations used: 
General Fund, Cemeteries and Memorials: $58,389,099; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $58,389,099; 
Total Funds, Total 2008: $53,079,263. 

Total Budgetary Financing Sources: 
General Fund, Cemeteries and Memorials: $58,389,099; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $58,389,099; 
Total Funds, Total 2008: $53,079,263. 

Other Financing Sources: 

Other revenue: 
General Fund, Cemeteries and Memorials: $64,010; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $64,010; 
Total Funds, Total 2008: [Empty]. 

Contributions: 
General Fund, Cemeteries and Memorials: $113,206; 
Trust Funds, WWII and Other Trust Funds: $559,748; 
Total Funds, Total 2009: $672,954; 
Total Funds, Total 2008: $494,693. 

Treasury investment earnings: 
General Fund, Cemeteries and Memorials: [Empty]; 
Trust Funds, WWII and Other Trust Funds: $21,068; 
Total Funds, Total 2009: $21,068; 
Total Funds, Total 2008: $136,314. 

Imputed financing: 
General Fund, Cemeteries and Memorials: $877,619; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $877,619; 
Total Funds, Total 2008: $733,261. 

Gain on disposition of assets: 
General Fund, Cemeteries and Memorials: $24,390; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $24,390; 
Total Funds, Total 2008: [Empty]. 

Total Other Financing Sources: 
General Fund, Cemeteries and Memorials: $1,079,225; 
Trust Funds, WWII and Other Trust Funds: $580,816; 
Total Funds, Total 2009: $1,660,041; 
Total Funds, Total 2008: $1,364,268; 

Total Financing Sources: 
General Fund, Cemeteries and Memorials: $59,468,324; 
Trust Funds, WWII and Other Trust Funds: $580,816; 
Total Funds, Total 2009: $60,049,140; 
Total Funds, Total 2008: $54,443,531. 

Less: Net Cost of Operations: 
General Fund, Cemeteries and Memorials: $59,017,224; 
Trust Funds, WWII and Other Trust Funds: $827,073; 
Total Funds, Total 2009: $59,844,297; 
Total Funds, Total 2008: $53,444,058. 

Net Increase (Decrease) for the Year: 
General Fund, Cemeteries and Memorials: $451,100; 
Trust Funds, WWII and Other Trust Funds: ($246,257); 
Total Funds, Total 2009: $204,843; 
Total Funds, Total 2008: $999,473. 

Cumulative Results (Deficit) - End of Year: 
General Fund, Cemeteries and Memorials: $16,776; 
Trust Funds, WWII and Other Trust Funds: $12,468,023; 
Total Funds, Total 2009: $12,484,799; 
Total Funds, Total 2008: $12,279,956. 

Unexpended Appropriations: 

Unexpended Appropriations - Start of Year: 
General Fund, Cemeteries and Memorials: $20,610,467; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $20,610,467; 
Total Funds, Total 2008: $18,061,682. 

Appropriations received: 
General Fund, Cemeteries and Memorials: $76,570,000; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $76,570,000; 
Total Funds, Total 2008: $55,600,000. 

Appropriations transferred in: 
General Fund, Cemeteries and Memorials: $500,000; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $500,000; 
Total Funds, Total 2008: [Empty]. 

Other offsetting receipts and adjustments: 
General Fund, Cemeteries and Memorials: ($23,802); 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($23,802); 
Total Funds, Total 2008: $28,048. 

Appropriations used: 
General Fund, Cemeteries and Memorials: ($58,389,099)		
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($58,389,099); 
Total Funds, Total 2008: ($53,079,263). 

Increase (decrease) in unexpended appropriations: 
General Fund, Cemeteries and Memorials: $18,657,099; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $18,657,099; 
Total Funds, Total 2008: $2,548,785. 

Unexpended Appropriations - End of Year: 
General Fund, Cemeteries and Memorials: $39,267,566; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $39,267,566; 
Total Funds, Total 2008: $20,610,467. 

Total Net Position - End Of Year: 
General Fund, Cemeteries and Memorials: $39,284,342; 
Trust Funds, WWII and Other Trust Funds: $12,468,023; 
Total Funds, Total 2009: $51,752,365; 
Total Funds, Total 2008: $32,890,423. 

The accompanying notes are an integral part of these statements. 

[End of Consolidating Statement of Net Cost and Changes in Net 
Position] 

Consolidating Statement of Budgetary Resources: 

American Battle Monuments Commission: 
Consolidating Statement Of Budgetary Resources: 
For the Year Ended September 30, 2009: 
(With Comparative Consolidated Total for the Year Ended September 30, 
2008): 

Budgetary Resources: 

Budgetary Authority: 

Appropriations: 
General Fund, Cemeteries and Memorials: $76,570,000; 	
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $$76,570,000; 
Total Funds, Total 2008: $55,600,000; 

Appropriations transferred in: 
General Fund, Cemeteries and Memorials: $500,000; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $500,000; 
Total Funds, Total 2008: [Empty]. 

Net transfer in for net foreign exchange loss: 
General Fund, Cemeteries and Memorials: $9,263,087; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $9,263,087; 
Total Funds, Total 2008: $7,626,087. 

Other (receipts collected): 
General Fund, Cemeteries and Memorials: $151,656; 
Trust Funds, WWII and Other Trust Funds: $580,816; 
Total Funds, Total 2009: $732,472; 
Total Funds, Total 2008: $727,342. 

Unobligated Balances: 

Start of year: 
General Fund, Cemeteries and Memorials: $12,254,197; 
Trust Funds, WWII and Other Trust Funds: $11,684,165; 
Total Funds, Total 2009: $23,938,362; 
Total Funds, Total 2008: $22,943,576. 

Net transfer (out) for net foreign exchange (loss): 
General Fund, Cemeteries and Memorials: ($9,263,087); 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($9,263,087); 
Total Funds, Total 2008: ($7,626,087); 

Other adjustments: 
General Fund, Cemeteries and Memorials: [Empty]; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: [Empty]; 
Total Funds, Total 2008: ($260,807). 

Total Budgetary Resources: 
General Fund, Cemeteries and Memorials: $89,475,853; 
Trust Funds, WWII and Other Trust Funds: $12,264,981; 
Total Funds, Total 2009: $101,740,834; 
Total Funds, Total 2008: $79,010,111. 

Status of Budgetary Resources: 

Obligations incurred-direct: 
General Fund, Cemeteries and Memorials: $61,504,420; 
Trust Funds, WWII and Other Trust Funds: $784,371; 
Total Funds, Total 2009: $62,288,791; 
Total Funds, Total 2008: $55,229,298. 

Unobligated balances available: 
General Fund, Cemeteries and Memorials: $27,971,433; 
Trust Funds, WWII and Other Trust Funds: $11,480,610; 
Total Funds, Total 2009: $39,452,043; 
Total Funds, Total 2008: $23,780,813. 

Total Status of Budgetary Resources: 
General Fund, Cemeteries and Memorials: $89,475,853; 
Trust Funds, WWII and Other Trust Funds: $12,264,981; 
Total Funds, Total 2009: $101,740,834; 
Total Funds, Total 2008: $79,010,111. 

Change in Obligated Balances: 

Obligations incurred for year: 
General Fund, Cemeteries and Memorials: $61,504,420; 
Trust Funds, WWII and Other Trust Funds: $784,371; 
Total Funds, Total 2009: $62,288,791; 
Total Funds, Total 2008: $55,229,298. 

Plus: Obligated balances, start of year: 
General Fund, Cemeteries and Memorials: $12,264,524; 
Trust Funds, WWII and Other Trust Funds: $1,072,973; 
Total Funds, Total 2009: $13,337,497; 
Total Funds, Total 2008: $14,116,670. 

Less: Adjustment to obligated balances: 
General Fund, Cemeteries and Memorials: [Empty]; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $0; 
Total Funds, Total 2008: ($4,735). 

Less: Gross outlays for year: 
General Fund, Cemeteries and Memorials: ($57,140,923); 
Trust Funds, WWII and Other Trust Funds: ($856,351); 
Total Funds, Total 2009: ($57,997,274); 
Total Funds, Total 2008: ($56,003,737). 

Obligated Balances, End of Year: 
General Fund, Cemeteries and Memorials: $16,628,021; 
Trust Funds, WWII and Other Trust Funds: $1,000,993; 
Total Funds, Total 2009: $17,629,014; 
Total Funds, Total 2008: $13,337,496. 

Net Outlays: 
				
Gross outlays for year: 
General Fund, Cemeteries and Memorials: $57,140,923; 
Trust Funds, WWII and Other Trust Funds: $856,351; 
Total Funds, Total 2009: $57,997,274; 
Total Funds, Total 2008: $56,003,737. 

Less: Offsetting collections: 
General Fund, Cemeteries and Memorials: ($151,656); 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($151,656); 
Total Funds, Total 2008: ($205). 

Net Outlays: 
General Fund, Cemeteries and Memorials: $56,989,267; 
Trust Funds, WWII and Other Trust Funds: $856,351; 
Total Funds, Total 2009: $57,845,618; 
Total Funds, Total 2008: $56,003,532. 

The accompanying notes are an integral part of these statements. 

[End of Consolidating Statement of Budgetary Resources] 

American Battle Monuments Commission: 
Notes To Consolidating And Consolidated Financial Statements: 
For the Fiscal Years Ended September 30, 2009 and 2008: 

Note 1. Significant Accounting Policies: 

A. Basis of Presentation: 

The accompanying consolidating and consolidated financial statements 
present the financial position, net cost of operations, changes in net 
position, and budgetary resources of the American Battle Monuments 
Commission (the Commission) in conformity with U.S. generally accepted 
accounting principles as used by the federal government. There are no 
intra-entity transactions to be eliminated. 

B. Reporting Entity and Funding Sources: 

The Commission is an independent agency within the executive branch of 
the federal government and was created by an Act of March 4, 1923, the 
current provisions of which are now codified in 36 U.S.C. Chapter 21. 
The Commission's mission is to commemorate the sacrifices and 
achievements of U.S. Armed Forces where they have served overseas since 
April 6, 1917, the date of the United States entry into World War I, 
and at locations within the United States when directed by the 
Congress. The Commission designs, administers, constructs, operates, 
and maintains 24 American military cemeteries and 25 federal memorials, 
monuments, and markers (herein collectively referred to as memorials). 
Three of the memorials are located in the United States while all of 
the cemeteries and the remaining memorials are located on foreign soil 
in 14 foreign countries, the Marianas, and Gibraltar. The Commission is 
also responsible for maintaining 7 nonfederal memorials with funds 
received from the memorials' sponsors. The Commission is headquartered 
in Arlington, Virginia. Field operations are conducted through regional 
offices located near Paris, France; and in Rome, Italy; and cemeteries 
in Manila, the Philippines; Mexico City, Mexico; and Panama City, 
Panama. 

The Commission also had responsibility for designing and constructing 
the National World War II Memorial located on the Mall in Washington, 
D.C. In accordance with 40 U.S.C. 8906(b), the Commission deposited 
$6.6 million into a separate Treasury account to offset the memorial's 
costs of perpetual maintenance. On November 1, 2004, the Commission 
signed an agreement with the National Park Service to formally transfer 
the National World War II Memorial to the Service for its future care 
and maintenance. Remaining funds reside in a trust fund in the U.S. 
Treasury to be used solely to benefit the World War II Memorial for 
other than routine maintenance expense. 

Commission programs are funded primarily through appropriations 
available without fiscal year limitation (no-year). The Commission also 
administers several trust funds established to: (1) build memorials 
authorized by the Congress, but which are funded primarily by private 
contributions, commemorative coin sales proceeds, and investment 
earnings; (2) decorate gravesites; and (3) maintain and repair certain 
nonfederal war memorials. 

C. Basis of Accounting: 

The Commission's proprietary accounts (assets, liabilities, equity, 
revenue, and expenses) are maintained on the accrual basis, where 
appropriated funds are accounted for by appropriation year; operating 
expenses are recorded as incurred; and depreciation is taken on 
property, plant, and equipment not otherwise classified as heritage 
assets. Commission budgetary accounts are maintained on a budgetary 
basis, which facilitates compliance with legal constraints and 
statutory funds control requirements. The functional budget 
classification is Veterans' Benefits and Services. 

D. Fund Balances with Treasury: 

The Commission's cash receipts and disbursements are processed by the 
U.S. Treasury. Fund balances with Treasury are composed of appropriated 
general funds and trust funds. 

E. Investments: 

In accordance with 36 U.S.C. 2113(b), the Commission is authorized to 
invest World War II Memorial Trust Fund receipts in U.S. Treasury 
securities. The Commission is also authorized under a modification to 
its original legislation to invest receipts from certain nonfederal war 
memorial organizations in U.S. Treasury securities. Treasury 
investments are recorded at par value plus unamortized premium or less 
unamortized discount. Premiums and discounts are amortized using the 
interest method. 

F. Foreign Currency: 

The Commission's overseas offices maintain accounts of foreign 
currencies to be used in making payments in foreign countries. Amounts 
are recorded at a standard budget rate in U.S. dollars and a gain or 
loss recognized when paid in foreign currency. Appropriated monies are 
transferred from the Commission's Foreign Currency Fluctuation Account 
to fund net currency losses. Cash accounts in foreign currencies are 
reported at the U.S. dollar equivalent using the Treasury exchange rate 
in effect on the last day of the fiscal year. 

G. Contributions and Revenue Recognition: 

The Commission recognizes unrestricted contributions or unconditional 
promises to give as revenue in the period of the initial pledge when 
sufficient verifiable evidence of the pledge exists. Conditional 
promises to give are recorded as revenue when the condition has been 
met. Unconditional promises to give may be temporarily restricted or 
permanently restricted. Temporarily restricted promises to give are 
released from restriction when the conditions have been met. 
Permanently restricted promises to give are recorded as revenue in the 
period donated; however, donors generally allow only the earned income 
to be used for general or specific purposes. In-kind contributions of 
goods and services are recognized at fair value by the Commission at 
the time the goods are received or the services are performed. 
Multiyear contributions due over a period of time are discounted to 
their present value based upon the short-term Treasury interest rate. 

H. Operating Materials and Supplies Inventories: 

The Commission has determined that operating materials and supplies 
located at its cemeteries are not significant amounts and that it is 
more cost beneficial to record them on the purchase method of 
accounting whereby items are expensed as purchased rather than when 
consumed. Consequently, the Commission reports no operating materials 
or supplies inventories. 

I. Property and Equipment: 

Purchases of general property and equipment of $25,000 or less are 
expensed in the year of acquisition. Purchases of personal property 
exceeding $25,000 are capitalized and depreciated on a straight-line 
basis over 5 years. Expenditures relating to real property exceeding 
$25,000 are capitalized and depreciated on a straight-line basis over 
30 years. Heritage assets are assets possessing significant cultural, 
architectural, or aesthetic characteristics. The Commission considers 
its cemeteries, and federal memorials, monuments, and markers acquired 
through purchase or donation to be noncollection heritage assets. 
Heritage assets acquired through purchase or donation are accounted 
for in the Commission's property records, and are not presented in the 
balance sheet. Withdrawals of heritage assets are recorded upon formal 
agreement with recipients. Additional disclosure on individual 
heritage asset cemeteries and memorials are found in the Schedules of 
Heritage Assets presented as unaudited other information. Cemetery 
land is owned by the foreign countries in which cemeteries are located 
and is provided to the United States in perpetuity. 

J. Employee Benefits: 

The Commission's civilian U.S. nationals hired after December 31, 1983 
are covered by the Federal Employees' Retirement System (FERS), which 
was implemented on January 1, 1984. The Commission's civilian U.S. 
nationals hired on or before December 31, 1983, could elect to transfer 
to FERS or remain with the Civil Service Retirement System (CSRS). For 
FERS employees, the Commission withholds .80 percent of base pay and as 
employer contributes 11.2 percent of base pay to this retirement 
system. For Federal Insurance Contribution Act (FICA) tax and Medicare, 
the Commission withholds 7.65 percent from FERS employees' earnings, 
matches this amount on a dollar-for-dollar basis, and remits the total 
amount to the Social Security Administration. The Commission withholds 
7.00 percent of base pay plus 1.45 percent for Medicare from CSRS 
employees' earnings and as employer contributes 7.00 percent of base 
pay plus 1.45 percent for Medicare. These deductions are then remitted 
to the Office of Personnel Management (OPM) and the Social Security 
Administration. OPM is responsible for governmentwide reporting of FERS 
and CSRS assets, accumulated plan benefits, and unfunded liabilities. 

On April 1, 1987, the federal government instituted the Thrift Saving 
Plan (TSP), a retirement savings and investment plan for employees 
covered by FERS and CSRS. The Commission contributes a minimum of 1 
percent of FERS employees' base pay to TSP. For 2009, FERS employees 
could contribute up to $16,500 ($22,000 if at least age 50) on a tax-
deferred basis to TSP, which the Commission matches up to 4 percent of 
base pay. For 2009, CSRS employees may also contribute up to $16,500 
($22,000 if at least age 50) on a tax-deferred basis; however, they 
receive no matching contribution from the Commission. 

Retirement and other benefits for the Commission's foreign national 
employees are paid by the Commission in accordance with the provisions 
of 10 host nation agreements negotiated by the U.S. Department of 
State. 

Annual leave is accrued as earned, and the resulting unfunded liability 
is reduced as leave is taken. Separation pay is provided in certain 
countries according to host nation agreements. Separation pay is 
accrued as earned, and the resulting unfunded liability is reduced when 
paid to the foreign national leaving the employ of the Commission. Each 
year balances in the accrued separation pay and annual leave accounts 
are adjusted to reflect current pay rates. To the extent that current 
or prior year appropriations are not available to fund annual leave and 
separation pay, funding will be obtained from future financing 
resources. Sick leave and other types of unvested leave are expensed 
when incurred. 

K. Imputed Financing: 

The Commission imputes financing for retirement and other benefits paid 
by OPM, financial audit costs incurred by the Government Accountability 
Office (GAO), and a heritage asset musical carillon donated each fiscal 
year. The Commission recognized these expenses and related imputed 
financing in its financial statements. A heritage asset musical 
carillon is also recognized each fiscal year as a donation by AMVETS 
and an in-kind expense. 

L. Use of Estimates: 

The preparation of financial statements requires management to make 
estimates and assumptions that affect the reported amount of assets and 
liabilities, as well as the disclosure of contingent assets and 
liabilities at the date of the financial statements, and the amount of 
revenues and expenses reported during the reporting period. Actual 
results could differ from those estimates. 

Note 2. Fund Balances with Treasury: 

All undisbursed account balances with the U.S. Treasury, as reflected 
in the Commission's records, as of September 30 are available and were 
as follows: 

Appropriated Funds: 
General Fund, 2009: $29,846,213; 
Trust Funds, 2009: [Empty]; 
Total, 2009: $29,846,213; 
Total, 2008: $17,830,649. 

Currency Fluctuation: 
General Fund, 2009: $14,432,339; 
Trust Funds, 2009: [Empty]; 
Total, 2009: $14,432,339; 
Total, 2008: $6,595,426. 

Other Trust Funds: 
General Fund, 2009: [Empty]; 
Trust Funds, 2009: $3,101,084; 
Total, 2009: $3,101,084; 
Total, 2008: $6,938,140. 

Total: 
General Fund, 2009: $44,278,552; 
Trust Funds, 2009: $3,101,084; 
Total, 2009: $47,379,636; 
Total, 2008: $31,364,215. 

Note 3. Treasury Investments, Net: 

As of September 30, the Commission's Trust Fund investments in U.S. 
Treasury notes, which are marketable securities due within 2 years were 
as follows: 

Net Premium Interest: 

FY: 2009; 
Cost: $8,832,026; 
Interest Rates: 4.250 to 5.750%; 
Net Premium/(Discount): $$461,929; 
Interest Receivable: $$86,758; 
Net Investment: $$9,380,713. 

FY: 2008; 
Cost: $5,700,000; 
Interest Rates: 4.625%; 
Net Premium/(Discount): $$30,912; 
Interest Receivable: $$87,875; 
Net Investment: $$5,818,787. 

Amortization is on the interest method, and amortized cost approximated 
market as of September 30. 

Note 4. Cash and Foreign Accounts: 

Outside the United States, the Commission makes payments in U.S. and 
foreign currencies through imprest cash funds and Treasury-designated 
depository commercial bank accounts, which as of September 30 were as 
follows: 

Imprest Cash Funds: 
2009: $45,380; 
2008: $46,746. 

Foreign Bank Accounts: 
2009: $183,291; 
2008: $44,527. 

Undeposited Cash-Trust: 
2009: 0; 
2008: $405. 

Total: 
2009: $228,671; 
2008: $91,678. 

Note 5. Contributions Receivable: 

The Commission has a pledge from a living trust valued at $134,203 as 
of September 30, 2009. However, due to the uncertainty of time and 
amount when the pledge is collected, the contribution will be 
recognized at the amount when received. 

Note 6. General and Heritage Property and Equipment: 

General property and equipment acquisitions with an aggregate cost 
basis of $25,000 or less and all acquisitions of heritage assets which 
totaled $2,887,482 were expensed by the Commission in fiscal year 2009. 
This included $1,532,186 related to the Normandy Visitor Center, a 
heritage asset. In fiscal year 2008, $4,694,825 was expensed, which 
included $4,061,634 of costs related to the construction of the 
Normandy Visitor Center. 

Since the 1960s, the Commission's European Regional Office near Paris, 
France, has occupied a residential structure owned by the United States 
government. The Commission is responsible for all utilities, 
maintenance, and repairs. While the structure has the characteristics 
of a heritage asset, it has been used as general property. However, it 
is now fully depreciated, and no value is contained in the Commission's 
financial statements. 

General property and equipment as of September 30 was as follows: 

Category: Buildings: 
2009: Cost: $923,460; 
2009: Accumulated Depreciation: $165,316; 
2009: Net: $758,144; 
2008: Cost: $923,710; 
2008: Accumulated Depreciation: $134,565; 
2008: Net: $789,145. 

Accounting Systems: 
2009: Cost: $2,145,016; 
2009: Accumulated Depreciation: $1,852,848; 
2009: Net: $292,168; 
2008: Cost: $2,039,026; 
2008: Accumulated Depreciation: $1,794,890; 
2008: Net: $244,136. 

Equipment: 
2009: Cost: $4,121,515; 
2009: Accumulated Depreciation: $2,288,449; 
2009: Net: $1,833,066; 
2008: Cost: $3,441,212; 
2008: Accumulated Depreciation: $2,119,354; 
2008: Net: $1,321,858. 

Total: 
2009: Cost: $7,189,991; 
2009: Accumulated Depreciation: $4,306,613; 
2009: Net: $2,883,378; 
2008: Cost: $6,403,948; 
2008: Accumulated Depreciation: $4,048,809; 
2008: Net: $2,355,139. 

Heritage assets are significant to the mission of the Commission to 
design, construct, and maintain historical cemeteries and memorials. 
The Commission presents its heritage assets in three categories; 
cemeteries, federal memorials, and nonfederal memorials. Changes in 
heritage assets for fiscal year 2009 were as follows: 

Beginning of Year 10-1-08: 
Cemeteries: 24; 
Federal Memorials: 25; 
Nonfederal Memorials: 7. 

Number Acquired, Fiscal Year 2009: 
Cemeteries: 0; 
Federal Memorials: 0; 
Nonfederal Memorials: 0. 

Number Withdrawn, Fiscal Year 2009: 
Cemeteries: 0; 
Federal Memorials: 0; 
Nonfederal Memorials: 0. 

End of Year 9-30-09: 
Cemeteries: 24; 
Federal Memorials: 25; 
Nonfederal Memorials: 7. 

Through September 30, 2009, Commission cemeteries contain over 131,000 
interments. Over 94,000 Honored War Dead, whose remains were not 
recovered, are memorialized in the cemeteries and federal memorials 
that encompass over 1,600 acres. This land is provided to the 
Commission through host agreements with foreign countries for permanent 
use as cemeteries and memorials. 

Note 7. Other Liabilities: 

Other liabilities as of September 30 were as follows: 

Accrued Salaries and Benefits: 
2009: $1,573,798; 
2008: $1,116,214. 

Unfunded Separation Pay Liability: 
2009: $1,674,295; 
2008: $1,634,931. 

Unfunded Annual Leave: 
2009: $1,268,319; 
2008: $1,154,727. 

Total: 
2009: $4,516,412; 
2008: $3,905,872. 

Under a host nation agreement, the Commission's Italian employees earn 
separation pay for each year of service with the Commission. The 
Commission recognized an unfunded liability for separation pay for 
these employees of $1,674,295 as of September 30, 2009, and $1,634,931 
as of September 30, 2008. 

A portion of pension and other retirement benefits (ORB) expense is 
funded by an imputed financing source to recognize the amount of 
pension and ORB unfunded liabilities assumed by OPM. These costs are 
computed in accordance with cost factors provided by OPM. For fiscal 
year 2009, the Commission incurred $1,331,151 of pension and ORB costs, 
$417,619 of which was imputed. For fiscal year 2008, the Commission 
incurred $1,111,431 of pension and ORB costs, $333,261 of which was 
imputed. Total imputed costs of $877,619 for fiscal year 2009 and 
$733,261 for fiscal year 2008 included audit services provided by GAO. 

Note 8. Lease Agreements: 

The Commission has no capital leases. The Commission's Arlington, 
Virginia, headquarters, including office space for the WWII Memorial 
Project, are rented under a 5-year operating lease expiring in July 
2012. 

In May 2008, the Commission's Mediterranean Regional Office moved from 
commercial leased space to the United States Embassy in Rome. Beginning 
in FY 2009, payment for the Rome office space is made through the 
International Cooperative Administrative Support Services (ICASS) 
program with the U.S. State Department. The Mediterranean Regional 
Office Director and Florence Cemetery Superintendent's living quarters 
are rented under operating leases expiring in December 2009 and 
September 2011, respectively. 

Living quarters for the Normandy Visitor Center Director and Assistant 
Director are rented under operating leases expiring in February 2013 
and May 2012, respectively. Six other living quarters leases for the 
benefit of the Commission's European Regional Office have been signed 
by the U.S. State Department and therefore, the Commission has no 
future liability for these leases. 

Rent expense for fiscal year 2009 operating leases was $777,859. Future 
minimum payments due on operating leases as of September 30, 2009, are 
as follows: 

Fiscal Year: 2010: $775,077; 
Fiscal Year: 2011: $719,809; 
Fiscal Year: 2012: $573,021; 
Fiscal Year: 2013: $5,488; 
Fiscal Year: 2014: 0; 
Fiscal Year: After 5 years: 0; 
Total: $2,073,395. 

Note 9. Net Position: 

Net position balances as of September 30, 2009, were as follows: 

Unexpended Appropriations: 

Unobligated: 
General Fund: $27,795,433[A]; 
Trust Funds: [Empty]; 
Total: $27,795,433. 

Undelivered Orders: 
General Fund: $11,472,133; 
Trust Funds: [Empty]; 
Total: $11,472,133. 

Total: 
General Fund: $39,267,566; 
Trust Funds: [Empty]; 
Total: $39,267,566. 

Cumulative Results of Operations (deficit): 

Unrestricted: 
General Fund: $16,776; 
Trust Funds: $11,480,804; 
Total: $11,497,580. 

Restricted for Undelivered Orders: 
General Fund: [Empty]; 
Trust Funds: $987,219. 
Total: $987,219; 

Total: 
General Fund: $16,776; 
Trust Funds: $12,468,023; 
Total: $12,484,799. 

Total Net Position: 
General Fund: $39,284,342; 
Trust Funds: $12,468,023; 
Total: $51,752,365. 

Net position balances as of September 30, 2008, were as follows: 

Unexpended Appropriations: 

Unobligated: 
General Fund: $12,254,197[B]; 
Trust Funds: $
Total: $12,254,197. 

Undelivered Orders: 
General Fund: $8,356,270; 
Trust Funds: $
Total: $8,356,270. 

Total: 
General Fund: $20,610,467; 
Trust Funds: $
Total: $20,610,467. 

Cumulative Results of Operations (deficit): 

Unrestricted: 
General Fund: ($434,324); 
Trust Funds: $11,684,165; 
Total: $11,249,841. 

Restricted for Undelivered Orders: 
General Fund: [Empty]; 
Trust Funds: $1,030,115; 
Total: $1,030,115. 

Total: 
General Fund: ($434,324); 
Trust Funds: $12,714,280; 
Total: $12,279,956. 

Total Net Position: 
General Fund: $20,176,143; 
Trust Funds: $12,714,280; 
Total: $32,890,423. 

[A] No-year appropriations received from FY 2002 through FY 2006 
totaling $30.0 million (after rescissions totaling $182,900) for design 
and construction of the Normandy Visitor Center were obligated by 
September 30, 2009. 

[B] Includes $2,580,891 unobligated for design and construction of the 
Normandy Visitor Center (after a $31,000 rescission) from a $3,100,000 
no-year appropriation for FY 2006. 

Note 10. Reconciliation of Net Cost of Operations to Budget: 

SFFAS No. 7 requires a reconciliation of proprietary and budgetary 
information in a way that helps users determine how budget resources 
obligated for programs relate to net costs of operations. Prior to 
fiscal year 2007, this reconciliation was accomplished by presenting a 
Statement of Financing as a basic financial statement. Effective for 
fiscal year 2007, the Office of Management and Budget in its Circular 
No. A-136, Financial Reporting Requirements, decided that this 
information for federal entities would be better placed and understood 
in a note. Consequently, this information is presented as follows: 

Resources Used To Finance Activities: 

Obligations incurred - direct: 
General Fund, Cemeteries and Memorials: $61,504,420; 
Trust Funds, WWII and Other Trust Funds: $784,371; 
Total Funds, Total 2009: $62,288,791; 
Total Funds, Total 2008: $55,229,298. 

Offsetting collections and recoveries: 
General Fund, Cemeteries and Memorials: ($36,623); 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($36,623); 
Total Funds, Total 2008: ($205). 

Imputed retirement and audit services: 
General Fund, Cemeteries and Memorials: $877,619; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $877,619; 
Total Funds, Total 2008: $733,261. 

Other adjustments: 
General Fund, Cemeteries and Memorials: $49,554; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $49,554; 
Total Funds, Total 2008: ($111). 

Total Resources Used to Finance Activities: 
General Fund, Cemeteries and Memorials: $62,394,970; 
Trust Funds, WWII and Other Trust Funds: $784,371; 
Total Funds, Total 2009: $63,179,341; 
Total Funds, Total 2008: $55,962,243. 

Resources That Do Not Fund Net Cost of Operations: 

General property capitalized on the balance sheet: 
General Fund, Cemeteries and Memorials: ($1,148,462); 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: ($1,148,462); 
Total Funds, Total 2008: ($1,118,784). 

Undelivered orders - start of year: 
General Fund, Cemeteries and Memorials: $8,356,270; 
Trust Funds, WWII and Other Trust Funds: $1,030,115; 
Total Funds, Total 2009: $9,386,385; 
Total Funds, Total 2008: $7,466,981. 

Less: Undelivered orders - end of year: 
General Fund, Cemeteries and Memorials: ($11,472,133); 
Trust Funds, WWII and Other Trust Funds: ($987,219); 
Total Funds, Total 2009: ($12,459,352); 
Total Funds, Total 2008: ($9,386,385). 

Total Resources That Do Not Fund Net Cost of Operations: 
General Fund, Cemeteries and Memorials: ($4,264,325); 
Trust Funds, WWII and Other Trust Funds: $42,896; 
Total Funds, Total 2009: ($4,221,429); 
Total Funds, Total 2008: ($3,038,188). 

Components of Net Cost of Operations Not Requiring Resources in the 
Current Period: 

Components Requiring Resources in Future Periods: 

(Decrease) increase in unfunded annual leave: 
General Fund, Cemeteries and Memorials: $113,787; 
Trust Funds, WWII and Other Trust Funds: ($194); 
Total Funds, Total 2009: $113,593; 
Total Funds, Total 2008: ($54,091). 

(Decrease) increase in unfunded separation pay liability: 
General Fund, Cemeteries and Memorials: $39,363; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $39,363; 
Total Funds, Total 2008: ($30,685). 

Components Not Requiring Resources: 

Depreciation: 
General Fund, Cemeteries and Memorials: $620,223; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $620,223; 
Total Funds, Total 2008: $569,772. 

In-kind expenses: 
General Fund, Cemeteries and Memorials: $113,206; 
Trust Funds, WWII and Other Trust Funds: [Empty]; 
Total Funds, Total 2009: $113,206; 
Total Funds, Total 2008: $35,007. 

Total Costs Not Requiring Resources in the Current Period: 
General Fund, Cemeteries and Memorials: $886,579; 
Trust Funds, WWII and Other Trust Funds: ($194); 
Total Funds, Total 2009: $886,385; 
Total Funds, Total 2008: $520,003. 

Total Resources Used to Finance the Net Cost of Operations: 
General Fund, Cemeteries and Memorials: $59,017,224; 
Trust Funds, WWII and Other Trust Funds: $827,073; 
Total Funds, Total 2009: $59,844,297; 
Total Funds, Total 2008: $53,444,058. 

[End of table] 

Note 11. Fiduciary Activities: 

Fiduciary activities are the collection or receipt, and the management, 
protection, accounting, investment and disposition by the Federal 
Government of cash or other assets in which non-Federal individuals or 
entities have an ownership interest that the Federal Government must 
uphold. 

Fiduciary cash and other assets are not assets of the Federal 
Government and accordingly are not recognized on the balance sheet. 

The Scottish Widows Defined Benefit Scheme was established by a Trust 
Deed, which authorized the Commission to collect contributions on 
behalf of beneficiaries, foreign service national employees of the 
Commission's two cemeteries in England. 

Schedule of Fiduciary Activity: As of September 30, 2009: 

Contributions: $454,197.
Investment earnings: $67,515.
Increases in fiduciary fund balances: $521,712.
Fiduciary net assets, beginning of year: $303,821.
Fiduciary net assets, end of year: $825,533. 

Fiduciary Net Assets: As of September 30, 2009: 

Fiduciary Assets: Investments: $825,533.
Total Fiduciary Assets: $825,533. 

[End of table] 

Note 12. Commitments and Contingencies: 

As of September 30, 2009 the Commission had commitments of $12.5 
million from undelivered orders as a result of open contracts and 
purchase orders. Also as of September 30, 2009 the Commission had 
pending administrative proceedings and personnel actions resulting from 
a reorganization in June 2009. These contingencies will be resolved by 
future events and are not expected to have a material effect on the 
financial statements. 

[End of Notes To Consolidating And Consolidated Financial Statements] 

Other Information: 

Required Supplemental Information: 

American Battle Monuments Commission:
Other Information:
September 30, 2009:
(Unaudited): 

Maintenance, Repairs, and Improvements: 

The following unaudited information is required supplementary 
information on deferred maintenance and the condition of real property 
at Commission cemeteries and memorials: 

Deferred maintenance is maintenance that was not performed when it 
should have been or was scheduled to be and that, therefore, is put off 
or delayed for a future period. Maintenance and repairs performed on 
real property consisting of land improvements, buildings, and memorials 
totaled $11.1 million in fiscal year 2009 and $5.6 million in fiscal 
year 2008. For fiscal years 1998 through 2002, the Commission received 
$11.3 million of additional appropriations from the Congress that 
enabled it to entirely eliminate its deferred maintenance backlog as of 
September 30, 2002. No deferred maintenance backlog existed as of 
September 30, 2009, and 2008. 

Condition assessment surveys, using a five-point scale of one 
(excellent) to five (very poor), identify needed future maintenance and 
repair projects at cemeteries and memorials in order to maintain real 
property in an acceptable condition of three (fair) or better. These 
surveys are reviewed and updated at least annually by the Commission's 
engineering staff. In addition, engineering projects identified 
improvements in cemetery irrigation, drainage, roads, parking areas, 
and buildings. As of September 30, 2009, the Commission has identified 
74 maintenance, repair, and improvement projects, with an estimated 
cost of $10.2 million, scheduled to be performed in fiscal year 2010, 
subject to available funding. 

Schedules of Heritage Assets: 

The following three pages present unaudited other information not 
required by U.S. generally accepted accounting principles on the 
Commission's 24 cemeteries; 25 federal memorials, monuments, and 
markers; and 7 nonfederal memorials as of September 30, 2009. 

[End of Other Information] 

Schedules of Heritage Assets: 

American Battle Monuments Commission: 
Schedule of Heritage Assets: 
September 30, 2009: 
(Unaudited): 

24 Cemeteries: 

European Region: 

Name: Aisne Marne American Cemetery; 
Location: Belleau (Aisne), France; 
Interred: 2,289; 
Memorialized: 1,060; 
Acres: 42.5; 
War: WW I. 

Name: Ardennes American Cemetery; 
Location: Neupre, Belgium; 
Interred: 5,325; 
Memorialized: 462; 
Acres: 90.5; 
War: WW II. 

Name: Brittany American Cemetery; 
Location: St. James (Manche), France; 
Interred: 4,410; 
Memorialized: 498; 
Acres: 27.9; 
War: WW II. 

Name: Brookwood American Cemetery; 
Location: Brookwood, England; 
Interred: 468; 
Memorialized: 563; 
Acres: 4.5; 
War: WW I. 

Name: Cambridge American Cemetery; 
Location: Cambridge, England; 
Interred: 3,812; 
Memorialized: 5,127; 
Acres: 30.5; 
War: WW II. 

Name: Epinal American Cemetery; 
Location: Epinal (Vosges), France; 
Interred: 5,255; 
Memorialized: 424; 
Acres: 48.6; 
War: WW II. 

Name: Flanders Field American Cemetery; 
Location: Waregem, Belgium; 
Interred: 368; 
Memorialized: 43; 
Acres: 6.2; 
War: WW I. 

Name: Henri-Chapelle American Cemetery; 
Location: Henri-Chapelle, Belgium; 
Interred: 7,992; 
Memorialized: 450; 
Acres: 57.0; 
War: WW II. 

Name: Lorraine American Cemetery; 
Location: St. Avold (Moselle), France; 
Interred: 10,489; 
Memorialized: 444; 
Acres: 113.5; 
War: WW II. 

Name: Luxembourg American Cemetery; 
Location: Luxembourg City, Luxembourg; 
Interred: 5,076; 
Memorialized: 371; 
Acres: 50.5; 
War: WW II. 

Name: Meuse-Argonne American Cemetery; 
Location: Romagne (Meuse), France; 
Interred: 14,246; 
Memorialized: 954; 
Acres: 130.5; 
War: WW I. 

Name: Netherlands American Cemetery; 
Location: Margraten, Holland; 
Interred: 8,301; 
Memorialized: 1,722; 
Acres: 65.5; 
War: WW II. 

Name: Normandy American Cemetery; 
Location: Colleville-sur-Mer, France; 
Interred: 9,387; 
Memorialized: 1,557; 
Acres: 172.5; 
War: WW II. 

Name: Oise-Aisne American Cemetery; 
Location: Fere-en-Tardenois, France; 
Interred: 6,012; 
Memorialized: 241; 
Acres: 36.5; 
War: WW I. 

Name: Somme American Cemetery; 
Location: Bony (Aisne), France; 
Interred: 1,844; 
Memorialized: 333; 
Acres: 14.3; 
War: WW I. 

Name: St. Mihiel American Cemetery; 
Location: Thiaucourt, Meurthe, France; 
Interred: 4,153; 
Memorialized: 284; 
Acres: 40.5; 
War: WW I. 

Name: Suresnes American Cemetery; 
Location: Seine, France; 
Interred: 1,565; 
Memorialized: 974; 
Acres: 7.5; 
War: WW I/II. 

Mediterranean Region: 

Name: Florence American Cemetery; 
Location: Florence, Italy; 
Interred: 4,402; 
Memorialized: 1,409; 
Acres: 70.0; 
War: WW II. 

Name: North Africa American Cemetery; 
Location: Carthage, Tunisia; 
Interred: 2,841; 
Memorialized: 3,724; 
Acres: 27.0; 
War: WW II. 

Name: Rhone American Cemetery; 
Location: Draguignan, Var, France; 
Interred: 861; 
Memorialized: 294; 
Acres: 12.5; 
War: WW II. 

Name: Sicily-Rome American Cemetery; 
Location: Nettuno, Italy; 
Interred: 7,861; 
Memorialized: 3,095; 
Acres: 77.0; 
War: WW II. 

Other: 

Name: Corozal American Cemetery; 
Location: Panama City, Panama; 
Interred: 5,374; 
Memorialized: 0; 
Acres: 16.0; 
War: Acquired by Executive Order from the former Panama Canal Zone. 

Name: Mexico City American Cemetery; 
Location: Mexico City, Mexico; 
Interred: 1,563	
Memorialized: 0; 
Acres: 1.0; 
War: Mex Am. 

Name: Manila American Cemetery; 
Location: Luzon, Phillipines; 
Interred: 17,202; 
Memorialized: 36,285; 
Acres: 152.0; 
War: WW II. 

Subtotal for Cemeteries:	
Interred: 131,096; 
Memorialized: 60,314; 
Acres: 1,294.5. 

25 Federal Memorials, Monuments, And Markers: 

Name: East Coast Memorial; 
Location: New York City, NY; 
Memorialized: 4,609; 
Acres: 0.8; 
War: WW II. 

Name: Honolulu Memorial; 
Location: Honolulu, HI; 
Memorialized: 28,800; 
Acres: 1.0; 
War: WW II/Korea/Vietnam. 

Name: West Coast Memorial; 
Location: San Francisco, CA; 
Memorialized: 412; 
Acres: 1.3; 
War: WW II. 

Name: Audenarde Monument; 
Location: Audenarde, Belgium; 
Acres: 0.4; 
War: WW I. 

Name: Bellicourt Monument; 
Location: St. Quentin, France; 
Acres: 1.8; 
War: WW I. 

Name: Brest Naval Monument; 
Location: Brest, France; 
Acres: 1.0; 
War: WW I. 

Name: Cabanatuan Memorial; 
Location: Luzon, Phillipines; 
War: WW II. 

Name: Cantigny Monument; 
Location: Cantigny, France; 
Acres: 0.4; 
War: WW I. 

Name: Chateau-Thierry Monument; 
Location: Chateau-Thierry, France; 
Acres: 58.9; 
War: WW I. 

Name: Chaumont Marker; 
Location: Chaumont, France; 
War: WW I. 

Name: Gibraltar Naval Monument; 
Location: Gibraltar; 
Acres: 0.1; 
War: WW I. 

Name: Guadalcanal Memorial; 
Location: Guadalcanal; 
Acres: 0.5; 
War: WW II. 

Name: Kemmel Monument; 
Location: Ypres, Belgium; 
Acres: 0.2; 
War: WW I. 

Name: Marine Monument Belleau Wood; 
Location: Aisne, France; 
Acres: 199.6; 
War: WW I. 

Name: Montfaucon Monument; 
Location: Montfaucon, France; 
Acres: 9.6; 
War: WW I. 

Name: Montsec Monument; 
Location: Thiaucourt, France; 
Acres: 47.5; 
War: WW I. 

Name: Papua Marker; 
Location: Port Moresby, New Guinea; 
War: WW II. 

Name: Pointe du Hoc Ranger Monument; 
Location: St. Laurent-sur-Mer, France; 
Acres: 29.8; 
War: WW II. 

Name: Saipan Monument; 
Location: Saipan, Northern Mariana Islands; 
War: WW II. 

Name: Santiago Surrender Tree; 
Location: Santiago, Cuba; 
War: Spanish-American War. 

Name: Sommepy Monument; 
Location: Sommepy, France; 
Acres: 15.0; 
War: WW I. 

Name: Souilly Marker; 
Location: Souilly, France; 
War: WW I. 

Name: Tours Monument; 
Location: Tours, France; 
Acres: 0.5; 
War: WW I. 

Name: Utah Beach Monument; 
Location: Sainte Marie-du-Mont, France; 
Acres: 0.5; 
War: WW II. 

Name: Western Naval Task Force Memorial; 
Location: Casablanca, Morocco; 
War: WW II. 

Subtotal for Memorials; 
Interred: 0; 
Memorialized: 33,821; 
Acres: 368.9. 

Grand Total: 
Interred: 131,096; 
Memorialized: 94,135; 
Acres: 1,663.4. 

7 Nonfederal Memorials: 

Name: 29th Infantry Division Memorial; 
Location: Vierville-sur-Mer, France; 
War: WW II. 

Name: 30th Infantry Division Memorial; 
Location: Mortain, France; 
War: WW II. 

Name: 6th Engineering Special Brigade Memorial; 
Location: Vierville-sur-Mer, France; 
War: WW II. 

Name: 351st Bomb Group Memorial; 
Location: Oundle, England; 
War: WW II. 

Name: 147th Engineer Battalion Monument; 
Location: Englesqueville-la-Percee, France; 
War: WW II. 

Name: 507th Parachute Infantry Regiment Memorial; 
Location: Amfreville, France; 
War: WW II. 

Name: 398th Bomb Group Memorial; 
Location: Herdfordshire, England; 
War: WW II. 

[End of Other Information] 

[End of section] 

Appendix I: Comments from the American Battle Monuments Commission: 

American Battle Monuments Commission: 
Courthouse Plaza II, Suite 500: 
2300 Clarendon Boulevard: 
Arlington, VA 22201-3367: 

February 17, 2010: 

Mr. Steven J. Sebastian: 
Director, Financial Management and Assurance: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Sebastian: 

The American Battle Monuments Commission's internal control over 
financial reporting is a process affected by those charged with 
governance, management, and other personnel, designed to provide 
reasonable assurance regarding the preparation of reliable financial 
statements in accordance with U.S. generally accepted accounting 
principles (GAAP). The Commission's internal control over financial 
reporting is designed to reasonably assure that (1) transactions are 
properly recorded, processed, and summarized to permit the preparation 
of financial statements in accordance with U.S. GAAP, and assets are 
safeguarded against loss from unauthorized acquisition, use, or 
disposition; and (2) transactions are executed in accordance with the 
laws governing the use of budget authority and other laws and 
regulations that could have a direct and material effect on the 
financial statements. 

Commission management is responsible for establishing and maintaining 
effective internal control over financial reporting. Commission 
management evaluated the effectiveness of its internal control over 
financial reporting as of September 30, 2009, based on the criteria 
established under 31 U.S.C. 3512 (commonly known as the Federal 
Manager's Financial Integrity Act). Based on that evaluation, we 
conclude that, as of September 30, 2009, the Commission's internal 
control over financial reporting was effective. 

Signed by: 

Max Cleland: 
Secretary: 

Signed by: 

Matthew Beck: 
Acting Chief Financial Officer: 

[End of section] 

Footnotes: 

[1] As defined by auditing standard AU 380.03a, those charged with 
governance are the person(s) with responsibility for overseeing the 
strategic direction of the entity and obligations related to the 
accountability of the entity, including overseeing the entity's 
financial reporting process. As applicable to a federal entity, this 
may include members of a board or commission, an audit committee, the 
Secretary of a cabinet-level department, or senior executives and 
financial managers responsible for the entity. 

[2] As defined by attestation standard AT 501.07, a significant 
deficiency in internal control is less severe than a material 
weakness, yet is important enough to merit attention by those charged 
with governance. A material weakness is a deficiency, or combination 
of deficiencies, in internal control over financial reporting, 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. 

[3] The Antideficency Act prohibits officers and employees of the U.S. 
government from obligating or spending in advance or in excess of 
appropriations. 31 U.S.C. §1341(a). The U.S. Supreme Court and the 
Comptroller General have held that open-ended indemnification 
agreements violate this prohibition in the absence of specific 
statutory authority. See Hercules, Inc. v. United States, 516 U.S. 
417, 427-28 (1996); B-242146, Aug. 16, 1991. 

[4] In accordance with the act, the violation and relevant facts, 
circumstances, and actions taken by the entity are to be reported to 
the Congress and the President of the United States, with a copy to 
the Comptroller General, following the guidance issued by OMB. 

[End of section] 

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