The Board's Law Enforcement Unit Could Benefit From Enhanced Oversight and Controls to Ensure Compliance With Applicable Regulations and Policies

Appendix A: Scope and Methodology

To assess the LEU’s compliance with Board and LEU internal policies and procedures and applicable laws, we reviewed records for the two-year period ending December 31, 2012. We interviewed LEU management and staff to gain an understanding of their processes for firearms, ammunition, credentials, and badges, and we interviewed staff from the RBOPS Protection Unit, which serves as the EOF for the Federal Reserve Banks’ LEUs, to gain insight into its inspection methodology. In addition, we interviewed RBOPS staff responsible for overseeing the Federal Reserve System Law Enforcement Training Manual to gain an understanding of the Federal Reserve System’s training requirements. We also completed the following steps:

• We reviewed the OIG’s 2009 inspection of the Board’s LEU, the Board’s Uniform Regulations for Federal Reserve Law Enforcement Officers, the LEU’s General Orders, the Federal Reserve System Law Enforcement Training Manual, and the Federal Reserve System’s Common Audit Programs.
• We reviewed IOC meeting minutes to assess the committee’s role and oversight of the LEU.
• We reviewed personnel records and the results of background investigations for 50 LEU officers to determine whether the minimum officer qualifications and standards were met.
• We performed a comprehensive inventory of all LEU badges, inspected records for badges and destroyed credentials for separated officers, and reviewed incident reports for lost or stolen credentials and badges to determine the accuracy of the LEU’s inventory records and its level of control over credentials and badges. We analyzed the LEU’s badge inventory records and determined that 204 badges were within our scope, 49 of which were unassigned. In addition, we analyzed the record of destroyed credentials for 34 officers who separated from the LEU during our scope.
• We performed a comprehensive inventory of all LEU firearms and ammunition to determine the accuracy of the LEU’s inventory records and its control over firearms and ammunition.
• We visited the Board’s Training Bureau and interviewed training staff to gain an understanding of how they document instructors’ and officers’ training and maintain training records. While at the Training Bureau, we reviewed instructors’ and officers’ training records.
• We reviewed training records for all nine instructors and for a sample of 50 officers. We selected a random sample of 30 officers who were employed as of January 1, 2010, and 20 officers hired during our scope.
• We reviewed Human Resources, Health Services, and Personnel Security records for our sample of 50 officers to determine compliance with LEU employment qualifications and standards.

We conducted our fieldwork from April 2013 through June 2013. We performed this inspection in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.