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Board Report: 2014-AE-B-006 March 28, 2014

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

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Finding 2: The LEU Did Not Effectively or Consistently Implement Established Controls to Account for Property

The LEU did not accurately and fully account for property assigned to officers, such as credentials and badges. Further, the LEU did not consistently document firearms inventory or complete ammunition inventories as required. We found that credentials were not destroyed in a timely manner, credentials and badges were not returned promptly, badge inventory records did not accurately reflect the inventory on hand, and some unassigned badges were not accounted for. In addition, daily firearms inventories were documented in an inconsistent manner; ammunition inventories were not performed on a quarterly basis; and property receipts were not used to ensure accountability of credentials, badges, and firearms assigned to or returned by officers. The General Orders requires the LEU to use property receipts when equipment is assigned to officers and for officers to return credentials, badges, and firearms on their last day of employment. Surrendered credentials are to be destroyed by the Administrative Section Commander of the Operations Support Bureau and surrendered badges returned to inventory. The General Orders also requires formal quarterly ammunition inventories to be performed. The LEU did not effectively or consistently implement established internal controls to ensure accountability and did not keep accurate inventory records for all unassigned items. Not having these internal controls increases the risk that theft of credentials, badges, firearms, and ammunition could go undetected.

Badge Inventory Records Were Not Accurate

The LEUís Operations Support Bureau did not adequately inventory and safely secure unassigned badges nor were inventory records updated in a timely manner. The General Orders states that LEU badges that have not been issued for use should be inventoried and stored in a safe. We compared the badges on hand to the most recent Badge Inventory Verification Record and found that the record did not reflect the actual number of unassigned badges on hand. We found 2 badges in the safe that were listed on the Badge Inventory Verification Record, but the physical location of the badges was not specified. We found that 5 of 49 badges (10 percent) listed as unassigned on inventory records were not stored in the safe. Three of these badges were discovered to have been assigned to officers. The other 2 badges could not be located. Upon further review, earlier inventory records for one of the 2 missing badges indicated that it had been assigned to an officer who had separated from the LEU.

In a review of officers who had separated from the LEU from 2010 through 2012, we found that the Badge Inventory Verification Record did not accurately report the disposition of the separated officersí badges. The personnel record we inspected showed that 34 officers separated from the LEU. The inventory record indicated that badges for 3 separated officers were still assigned to them; however, we were able to locate these badges in the safe during our inventory.

We brought the inaccuracies on the Badge Inventory Verification Record and the 2 missing badges to the attention of the Deputy Chief of Operations Support, who acknowledged that the Badge Inventory Verification Record was neither current nor accurate. As a result, the LEU filed an incident report for both missing badges. The Deputy Chief of Operations Support stated that he would strengthen the practice for storing and inventorying unassigned badges to improve accountability.

Insufficient Evidence That Credentials for Separated Officers Were Destroyed

The LEUís Operations Support Bureau did not always ensure that credentials were destroyed or rendered void as required when officers separated from the Board or ensure that credentials were destroyed in a timely manner. We compared records of employee separations from 2010 through 2012 to the LEUís spreadsheet documenting the final disposition of credentials and found that the Operations Support Bureau did not record the disposition of credentials for 21 of the 34 officers (65 percent) who separated. Neither the Uniform Regulations for Federal Reserve Law Enforcement Officers nor the General Orders specifies a time frame for destroying or voiding the credentials of separating officers. We found that, on average, the LEU destroyed credentials 45 days after a separation; however, in one instance, the LEU destroyed a credential 232 days after a separation. The General Orders states that when an officer separates from the Board, the credential will be turned in on the last day of employment and appropriately disposed.

We brought these issues to the attention of the Deputy Chief of Operations Support. He stated that he was unaware of the spreadsheet to record the final disposition of credentials.

Daily Firearms Inventory Records Were Not Documented Consistently

The Operations Bureau did not consistently document the daily firearms inventory reports. On a daily basis, the Operations Bureauís on-duty Shift Commander, or his or her designee, performs an inventory of all of the unitís assigned firearms by visually inspecting all gun lockers, documenting each firearmís presence or absence, and reconciling any missing firearms to the shift roster. The inventory takes place after the beginning of each shift, and there are three shifts per day. At the conclusion of each shift, the Shift Commander submits the inventory report to the Administrative Section Commander.

During our testing, we judgmentally selected 25 shifts from 2010 through 2012 to verify that daily firearm inventories were performed. Although Shift Commanders performed inventories and submitted inventory reports as required, we found inconsistencies with the completion of daily inventory reports. We found the following:

  • Reconciliations were not routinely performed. One report did not record the inventory status for the majority of the firearms listed. Another report indicated that one firearm was unaccounted for; however, after further inquiry, we learned that the firearm was accounted for and had been moved from the gun box by the officer performing the inventory because the officer to whom it was assigned was on suspension.
  • Inventory reports were incomplete. The name of the officer performing the inventory was written in the comments column for three firearms, but checkboxes to indicate that the firearms were accounted for were not marked. In these instances, the officer removed the three firearms from the gun box because the assigned officers were no longer in an active-duty status.

Formal Quarterly Ammunition Inventories Were Not Performed

The LEUís Operations Support Bureau did not perform an inventory of all ammunition on a quarterly basis as required. We did find, however, that inventory records showed the date and name of the officer who added or removed ammunition from the ammunition vault. We reviewed Ammunition Inventory Logs from 2010 through 2012 and observed that the LEU maintains a running inventory that documents when ammunition is added or removed from the vault but does not document the total amount of ammunition on hand. To perform our inventory, we calculated the total amount of ammunition in the vault based on the LEUís running inventory and determined that all ammunition listed on the 2013 Ammunition Inventory Log was accounted for. The Uniform Regulations for Federal Reserve Law Enforcement Officers states that each LEU will adopt procedures for the maintenance of records with respect to the issuance, proper care, storage, and maintenance of firearms and ammunition. The General Orders states that the Boardís LEU will perform a formal quarterly inspection of ammunition.

Property Receipts Were Not Used

The LEUís Operations Support Bureau no longer issues property receipts when credentials, badges, and firearms are assigned to or returned by officers. The bureau does, however, maintain inventory records of these items that identify the officer to whom the item was issued. We performed an inventory of firearms by comparing the master inventory to the serial numbers on unassigned and assigned weapons and found that all firearms were accounted for. However, the inventory records do not indicate the date firearms were issued or include the signature of the officer acknowledging receipt or return of the firearm. We also found that records for credentials and badges do not include the date of issuance and an officerís signature showing that he or she received these items. The General Orders requires that the LEU use property receipts to ensure accountability of LEU-issued credentials, badges, and firearms. In addition, items such as credentials, badges, and firearms should be issued to officers at the completion of basic training. Because the LEU no longer uses property receipts to record the assignment of credentials, badges, and firearms to officers, the LEU does not have evidence indicating when these items were assigned to an officer.

We learned that the use of property receipts was discontinued when the previous Administrative Section Commander, responsible for issuing property receipts, was replaced. The Deputy Chief of Operations Support stated that he was unaware of the discontinued use but stated that property receipts will be used going forward.

Recommendations

We recommend that the Chief of the LEU

  1. Strengthen accountability and control over credentials and badges by
    1. requiring that periodic updates of inventory records be signed and dated certifying items on hand and those that have been assigned.
    2. requiring a second-level review of each inventory update, to include signed and dated records certifying that the review was completed.
  2. Require that credentials be destroyed or rendered void within one week of officer separation from the LEU, and require the LEU Operations Support Bureau to prepare and maintain an administrative record of the disposition.
  3. Ensure that the daily firearms inventory is documented in a consistent manner and that a second-level review of the inventory is performed and documented.
  4. Strengthen accountability and control over ammunition by
    1. requiring formal quarterly inventories of all ammunition, to include signed and dated records certifying that the inventory was completed.
    2. requiring a second-level review of each quarterly inventory, to include signed and dated records certifying that the review was completed.
  5. Require evidence confirming officersí receipt of credentials, badges, and firearms when these items are issued and evidence confirming their return when officers separate from the LEU. The evidence should include relevant information describing the property as well as the appropriate dates and signatures.

Managementís Response

The Director of the Management Division generally concurred with recommendations 3 through 7. In his response, the Director indicated that steps have already been taken to strengthen the accountability of LEU property, to include properly tracking and inventorying credentials and badges, recording the destruction of credentials when officers separate from the LEU, and conducting an annual inventory of all serialized property. In addition, the Director reported that supervisory staff have been retrained on firearms and ammunition inventory, and a secondary review of all inventories each month has been instituted. The Director also noted in his response that the LEU is in the process of identifying a ďscalable inventory system capable of tracking all real property belonging to the unit,Ē which will assist the LEU in ensuring accountability for critical assets. Managementís full response is included as appendix B.

OIG Comment

In our opinion, the actions described by the Director of the Management Division are responsive to our recommendations. We acknowledge that the steps described are likely to address recommendations 3 through 6, and in one instance, the prescribed actions exceed the recommendation for quarterly second-level reviews of ammunition by stating that such reviews are conducted monthly. Recommendation 7 calls for evidence confirming officersí receipt of property when credentials, badges, and firearms are assigned, as well as when that property is returned. While the Directorís response does not address these actions specifically, we encourage the Director to include the capability to capture an officerís acknowledgement of receiving or returning these critical assets in the proposed inventory management system. We plan to follow up on actions taken by the LEU to ensure that our recommendations are fully addressed.