Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller), in coordination with the U.S. Army, Air Force, Navy, and Marine Corps, conduct a review of the foreign currency rates used at disbursement to determine whether cost-saving opportunities exist by more consistently selecting cost-effective rates at disbursement. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions to update Volume 6A, Chapter 7 of the Financial Management Regulation (FMR) with guidance on rates for disbursement to ensure all components are utilizing the most cost-effective rates while balancing mission requirements and time required to process transactions. DOD estimates that the FMR revision will be completed by October 31, 2020. Until the revision to the FMR is completed, DOD risks paying more to disburse funds for overseas expenditures than would otherwise be required.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller) analyze realized and projected losses to determine the necessary size of the FCFD account balance and use the results of this analysis as the basis for transfers of unobligated balances to the account. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. However, as of August 2019, DOD had not planned any actions intended to implement this recommendation. According to DOD, projecting foreign currency gains or losses to determine the necessary size of the Foreign Currency Fluctuations, Defense (FCFD) account balance would only be possible if foreign currency rates do not fluctuate. DOD states that if projected gains or losses are used to determine the necessary size of the FCFD account when foreign currency rates are volatile, it would expose the department to additional risk. In our report, we acknowledged the inherent challenge in projecting foreign currency gains or losses. However, we also noted that DOD already projects foreign currency gains or losses as the basis for transfers out of the FCFD account but does not use the same analysis to inform its transfers into the account. Further, DOD has the flexibility to make multiple transfers of funds to the FCFD account in a fiscal year in response to any unforeseen foreign currency fluctuations. Without an analysis of projected losses to determine the necessary size of the account balance, DOD may be maintaining the account at a higher balance than is necessary and losing opportunities to more efficiently use funds.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller) revise the Financial Management Regulation to include guidance on ensuring that data are complete and accurate, including assignment of responsibility for correcting erroneous data in its Foreign Currency Fluctuations Defense (O&M) reports. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions to revise Volume 6A, Chapter 7 of the Financial Management Regulation (FMR) to ensure reporting is complete and accurate and assign responsibilities to DOD components for data correction. DOD estimates that the revision to the FMR will be completed by October 31, 2020. Without updated guidance to ensure that the data that tracks foreign currency gains and losses are complete, DOD and Congress will continue to lack quality information with which to make decisions and exercise stewardship over resources for managing foreign currency fluctuations.

Recommendation: The Secretary of Defense should ensure that the Secretary of the Army develop a plan with timelines for implementing changes to its General Fund Enterprise Business System to accurately record its disbursements, consistent with DOD Financial Management Regulation guidance. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions intended to address the recommendation. Specifically, the Secretary of the Army intended to develop a Systems Change Request for how disbursements are recorded in the General Fund Enterprise Business System to be consistent with DOD's Financial Management Regulation. DOD estimates that the system changes will be complete by the second quarter of FY 2020. Until DOD completes its planned actions to address this recommendation, the Army and DOD will continue to lack accurate information for tracking and helping to manage foreign currency gains and losses.