The Secretary of the Treasury, in coordination with the Director of the Office of Management and Budget (OMB), is required to annually prepare and submit audited financial statements of the U.S. government to the President and the Congress. We are required to audit these consolidated financial statements (CFS) and report on the results of our work. In connection with fulfilling our requirement to audit the fiscal year 2004 CFS, we evaluated the Department of the Treasury's (Treasury) financial reporting procedures and related internal control over the process for compiling the CFS, including the management representation letter provided us by Treasury and OMB. Written representation letters from management, required by U.S. generally accepted government auditing standards, ordinarily confirm oral representations given to the auditor, indicate and document the continuing appropriateness of those representations, and reduce the possibility of a misunderstanding between management and the auditor. The purpose of this report is to communicate our observations on the Department of Commerce's (DOC) fiscal year 2004 management representation letter. Our objective is to help ensure that future management representation letters submitted by DOC are sufficient to help support Treasury and OMB's preparation of the CFS management representation letter and our ability to rely on the representations in that letter in combination with individual federal agency representation letters. We reviewed five key areas in each management representation letter: (1) signatures, (2) materiality thresholds, (3) representations, (4) summary of unadjusted misstatements, and (5) reliability of representations. In reviewing the management representation letters, we applied the American Institute of Certified Public Accountants' (AICPA) Codification of Auditing Standards, AU Section 333, Management Representations; OMB Bulletin 01-02, Audit Requirements for Federal Financial Statements; and the GAO/President's Council on Integrity and Efficiency (PCIE) Financial Audit Manual (FAM) section 1001, entitled "Management Representations."

DOC's fiscal year 2004 management representation letter, as well as several other federal agencies' management representation letters, did not provide all the information necessary to support Treasury and OMB's preparation of the CFS management representation letter. This in turn impacted our ability to rely on the representations in the CFS management representation letter in combination with individual federal agency representation letters. We identified some needed improvements in one of the five key areas we reviewed. Specifically, the letter included 27 of the 29 representations from the FAM that were applicable to DOC. For the other 2 representations, 1 was not fully included and 1 was not provided at all. We believe that this matter can be easily addressed and are making a recommendation to DOC's Chief Financial Officer to ensure future management representation letters fully include all representations from the FAM that are applicable to DOC. Also, we are recommending that the DOC Inspector General, with the contracted independent public accountant, work with the department to help ensure that future management representation letters meet the key condition noted as needing improvements in this report.

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