Recommendation: The Secretary of Defense should ensure that written ACSA guidance includes recordkeeping procedures related to ACSA congressional notifications and signature dates to help enable the provision of complete information for Congress. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. At that time, DOD provided a copy of a February 2020 memorandum issued in response to our draft recommendation that outlined procedures to capture and preserve information about ACSA establishment, including the dates of DOD's congressional notifications of intent to designate countries for ACSAs and agreement signature dates. In April 2020, DOD provided evidence confirming appropriate distribution of the memorandum. As of May 2020, we continue to work with DOD officials to secure evidence confirming its implementation.

Recommendation: The Secretary of Defense should take steps to verify the accuracy of ACSA order statuses recorded in DOD's system of record, and make corrections as appropriate. (Recommendation 3)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. As we confirm DOD efforts in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should implement a process to reconcile data in financial systems with the data and associated documents collected and stored in DOD's ACSA system of record on a periodic basis. (Recommendation 4)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. As we confirm DOD efforts in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should develop and implement a mechanism to record and track the extent to which it is meeting required time frames to receive reimbursement for ACSA orders. (Recommendation 5).

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. As we confirm DOD efforts in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should take steps to improve invoicing of ACSA orders, such as identifying ACSA orders recorded in DOD's system of record that have not been invoiced and sending invoices to partner countries. (Recommendation 6)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. As we confirm DOD efforts in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should implement a process to monitor ACSA orders recorded as overdue in DOD's system of record, and take steps to resolve outstanding reimbursements, as appropriate. (Recommendation 7)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: DOD concurred with this recommendation in its official comment letter included as an appendix in GAO-20-309, published in March 2020. As we confirm DOD efforts in response to this recommendation, we will provide updated information.

Recommendation: The Program Director for Financial Integration should collect and document requirements to define project scope and meet project objectives. These requirements should be updated periodically throughout the life of the project. (Recommendation 2)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of August 2020, NNSA provided a project plan for tasks to be completed for common financial reporting through 2021. However, NNSA has not developed requirements that define specific or detailed requirements for successful implementation of common financial reporting, such as the types of information that program managers need.

Recommendation: The Program Director for Financial Integration should develop a detailed project schedule. The detailed schedule should be documented as part of the annual report to Congress required in the National Defense Authorization Act for Fiscal Year 2017. (Recommendation 3)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of August 2020, NNSA established a detailed project schedule for the common financial reporting effort through fiscal year 2021. However, NNSA should communicate this detailed project schedule for the effort to Congress on an annual basis.

Recommendation: The Program Director for Financial Integration should develop a formal process to identify risks, document those risks, and plan how to minimize risk exposure. (Recommendation 6)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: In June 2020, NNSA developed a risk management plan for common financial reporting which established a framework for identifying and managing risks. GAO will continue to monitor NNSA's efforts to implement the plan, including how NNSA identifies and documents risks and mitigates risk exposure using its management plan.

Recommendation: The Program Director for Financial Integration should develop an approach to effectively engage with all project stakeholders that incorporates their expectations into project decisions. (Recommendation 7)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of September 2020, NNSA has continued to engage on a regular basis with its M&O contractors. However, similar efforts have not continued with stakeholders of the program offices.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by entering correct contractor password expiration dates, per IRS's policy, in the system used for managing user access authorizations. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by documenting access authorizations for non-unique accounts. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by reviewing non-unique accounts at least annually, per IRS's policy. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

Recommendation: To strengthen the scenario design process, the Federal Reserve should assess--and adjust as necessary--the overall level of severity of its severely adverse scenario by expanding consideration of the trade-offs associated with different degrees of severity.

Agency: Federal Reserve System
Status: Open
Priority recommendation

Comments: In January 2019, the Federal Reserve said it had initiated two projects that would allow a more efficient evaluation of multiple scenarios, including assessing trade-offs associated with different levels of scenario severity. In December 2019, Federal Reserve staff provided updates on these projects, which remain in progress. We will continue to monitor the Federal Reserve's completion and implementation of these projects and any additional actions it takes that may be responsive to our recommendation.

Recommendation: To improve understanding of the range of potential crises against which the banking system would be resilient and the outcomes that might result from different scenarios, the Federal Reserve should assess whether a single severe supervisory scenario is sufficient to inform CCAR decisions and promote the resilience of the banking system. Such an assessment could include conducting sensitivity analysis involving multiple severe supervisory scenarios--potentially using CCAR data for a cycle that is already complete, to avoid concerns about tailoring the scenario to achieve a particular outcome.

Agency: Federal Reserve System
Status: Open
Priority recommendation

Comments: In January 2019, the Federal Reserve said it had initiated two projects that would allow a more efficient evaluation of multiple scenarios. In December 2019, Federal Reserve staff provided updates on these projects, which remain in progress. We will continue to monitor the Federal Reserve's completion and implementation of these projects and any additional actions it takes that may be responsive to our recommendation.

Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process to test and document the sensitivity and uncertainty of the model system's output--the post-stress capital ratios used to make CCAR quantitative assessment determinations--including, at a minimum, the cumulative uncertainty surrounding the capital ratios and their sensitivity to key model parameters, specifications, and assumptions from across the system of models.

Agency: Federal Reserve System
Status: Open
Priority recommendation

Comments: In January 2019, the Federal Reserve said it had previously initiated multiple projects to fully respond to our recommendation, several of which were now complete. In December 2019, Federal Reserve staff provided updates on the remaining projects, which remain in various stages of completion. We will continue to monitor the Federal Reserve's completion and implementation of these projects and, once we receive documentation demonstrating the completion of responsive actions, we will update the status of this recommendation.

Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process to communicate information about the range and sources of uncertainty surrounding the post-stress capital ratio estimates to the Board during CCAR deliberations.

Agency: Federal Reserve System
Status: Open
Priority recommendation

Comments: In January 2019, the Federal Reserve said it had previously initiated a project to fully respond to our recommendation. In December 2019, Federal Reserve staff provided updates on the project, but as of February 2020, had not provided documentation fully supporting implementation of a process consistent with our recommendation. We will continue to monitor the Federal Reserve's completion and implementation of this project, and we will update the status of this recommendation once we receive documentation demonstrating the completion of responsive actions.

Recommendation: To improve the Federal Reserve's ability to manage model risk and ensure that decisions based on supervisory stress test results are informed by an understanding of model risk, the Federal Reserve should design and implement a process for the Board and senior staff to articulate tolerance levels for key risks identified through sensitivity testing and for the degree of uncertainty in the projected capital ratios.

Agency: Federal Reserve System
Status: Open
Priority recommendation

Comments: In January 2019, the Federal Reserve said it had previously initiated a project to fully respond to our recommendation. In December 2019, Federal Reserve staff provided updates on the project, but as of February 2020, had not provided documentation fully supporting implementation of a process consistent with our recommendation. We will continue to monitor the Federal Reserve's completion and implementation of this project, and we will update the status of this recommendation once we receive documentation demonstrating the completion of responsive actions.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to define a high-level depiction of the IT systems anticipated in the future state, a description of the operations that must be performed and who must perform them, and an explanation of where and how the operations are to be carried out.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had collaborated through an IT technical assessment initiative, identifying four primary financial management modernization initiatives remaining from the New Core Program. In July 2020, HUD officials, including the Deputy Chief Financial Officer, provided a roadmap that defined a high-level depiction of the financial management systems anticipated in the future state. However, the department had not yet completed more detailed plans that (1) identify operations that must be performed and who must perform them and (2) explain where and how operations are to be carried out. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to develop comprehensive plans for scope, schedule and cost.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization. As of July 2020, the department had begun taking action to address this recommendation. Specifically, HUD planned to integrate loan and property management into its current financial management shared service and had begun planning for how to modernize its budget formulation and cost accounting systems. For the budget formulation effort, HUD had developed high-level plans for the scope of the program, planned an implementation schedule, and estimated on the cost for implementation and operating and maintaining the system for two years. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to ensure requirements are fully documented and traceable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In March 2017, the department reported that the Chief Financial Officer and the Chief Information Officer intended to partner on future departmental financial management systems modernization efforts to fully document requirements and trace requirements to the functionality in the modernized system. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. As of July 2020, HUD was in the early phases of planning for modernization in these areas. According to officials from the Office of the Chief Financial Officer, the department intended to address this recommendation for budget formulation modernization by developing applicable plans and artifacts for managing requirements from the department's project planning and management framework. However, that effort has not yet started. We intend to continue to follow up on HUD's actions.

Recommendation: The Secretary of HUD should also direct the Deputy Secretary to ensure that the Chief Information Officer takes action to improve IT governance control activities used for monitoring programs and identifying needed corrective actions, and strengthen investment oversight by improving coordination with stakeholders and alignment among IT modernization efforts.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. Since 2016, HUD has revised its IT governance boards, which provide oversight of all its IT investments, including financial management initiatives, several times. While the department has not yet completed those improvement efforts, HUD updated its project planning and management framework to tailor requirements and artifacts for different program types. According to an official from the Office of the Chief Financial Officer, updates to the requirements for shared services projects incorporated lessons learned from the New Core program. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. Officials from both offices have described improvements in their coordination and collaboration on efforts to plan for modernization. We intend to continue to follow up on HUD's actions to ensure that planned improvements to governance and oversight mechanisms are effectively implemented and institutionalized.

Recommendation: Congress should consider whether additional changes to the financial regulatory structure are needed to reduce or better manage fragmentation and overlap in the oversight of financial institutions and activities to improve (1) the efficiency and effectiveness of oversight; (2) the consistency of consumer and investor protections; and (3) the consistency of financial oversight for similar institutions, products, risks, and services. For example, Congress could consider consolidating the number of federal agencies involved in overseeing the safety and soundness of depository institutions, combining the entities involved in overseeing the securities and derivatives markets, transferring the remaining prudential regulators' consumer protection authorities over large depository institutions to the Consumer Financial Protection Bureau, and the optimal role for the federal government in insurance regulation, among other considerations.

Agency: Congress
Status: Open

Comments: At least two bills have been introduced in the 115th Congress that would change the financial regulatory structure, to some degree, to address fragmented and overlapping regulatory authorities among agencies, as GAO suggested in February 2016. The Financial CHOICE Act of 2017 (H.R. 10) was introduced on April 26, 2017, passed the House in June 2017 and the Senate held hearings in July 2017. Among other things, the Financial CHOICE Act of 2017 calls for the federal financial regulatory agencies to implement policies and procedures to minimize the duplication of effort with respect to enforcement actions. For example, it eliminates the authority of the Consumer Financial Protection Bureau to supervise and examine financial institutions and also eliminates the regulatory and enforcement authority of the agency with respect to unfair, deceptive, and abusive acts and practices by depository institutions. Such actions could help reduce fragmentation and overlap in the financial regulatory structure. In addition, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155) was introduced on November 16, 2017 and passed in the Senate in March 2018. The bill, to some extent, may help address fragmentation, overlap, and duplication in the financial regulatory structure. For example, the bill helps to address fragmentation in insurance oversight by finding that the federal agencies and office involved in insurance regulation should achieve consensus with state insurance regulators when they participate in negotiations on insurance issues before any international forum of financial regulators or supervisors, and create an advisory committee to discuss and report on insurance policy issues including international issues. GAO will continue to monitor the reform efforts to determine the extent to which they could help to address fragmentation and overlap between the federal financial regulatory agencies and reduce opportunities for inefficiencies in the regulatory process and inconsistencies in how regulators conduct oversight activities over similar types of institutions, products, and risks.

Recommendation: Congress should consider whether legislative changes are necessary to align FSOC's authorities with its mission to respond to systemic risks. Congress could do so by making changes to FSOC's mission, its authorities, or both, or to the missions and authorities of one or more of the FSOC member agencies to support a stronger link between the responsibility and capacity to respond to systemic risks. In doing so, Congress could solicit information from FSOC on the effective scope of its collective designation authorities, including any gaps.

Agency: Congress
Status: Open

Comments: While some legislative action has been taken that may alter FSOC's authorities, it is not clear that the legislation would address GAO's February 2016 suggestion. The Financial CHOICE Act of 2017 (H.R. 10) was introduced on April 26, 2017, passed the House in June 2017, and the Senate held hearings in July 2017. The bill would change FSOC's authorities by repealing its authorities to designate non-bank financial institutions and financial market utilities (i.e., payment, clearing, and settlement systems) as "systemically important." In addition, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155) was introduced on November 16, 2017 and passed in the Senate in March 2018. The bill may alter some of FSOC's authorities. However, it is unclear if these acts would alter FSOC's mission to better align it with its authorities to respond to systemic risk or addresses a gap in systemic risk mitigation mechanisms. Without legislative changes that would align FSOC's authorities with its mission, FSOC may lack the tools it needs to comprehensively address systemic risks that may emerge and a gap will continue to exist in the mechanisms for mitigating systemic risks. GAO will continue to monitor the reform efforts to determine the extent to which they help to align FSOC's authorities with its mission to respond to systemic risks.