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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 3: The LEU Training Bureau Did Not Ensure That All Training and Recertification Requirements Were Documented or Met

The LEU’s Training Bureau did not ensure that instructors and officers complied with Federal Reserve System training and certification requirements. We found that officers were trained by LEU instructors who did not have sufficient documentation indicating that training and certification requirements were met. In addition, we found instances in which there was no documentation to indicate that officers completed all required courses. The General Orders states that “it is Unit policy to comply with the requirements of the Federal Reserve System in regards to the training of Board Law Enforcement Officers.” The Federal Reserve Law Enforcement Training Manual requires LEU instructors to attend instructor training and maintain certifications; further, the manual requires officers to complete basic training before being sworn in and to attend in-service training annually. The Training Bureau did not have controls to help it ensure that training and recertification requirements were met. Insufficient internal controls regarding LEU training and recertification exposes the Board to potential liability for any inadequate or improper actions taken by officers and increases the Board’s reputational risk.

Training Bureau Did Not Routinely Document Instructor Training and Recertification

We did not find evidence that the Board’s LEU instructors satisfied all training and recertification requirements. The training records for all nine course instructors showed that they maintained general instructor certifications and that seven instructors who taught high-liability topics had maintained specialized certifications in those areas.3 However, we did not find evidence of course completion or recertification for the following:

  • six instructors who were required to complete a minimum of 40 hours of advanced training in instructor skills every three years prior to 2012
  • six instructors who were required to complete 4 hours of instructor skills training in 2012
  • five instructors who were required to complete advanced or recertification training within 3 years of their certification
  • two instructors who were required to maintain their certifications in defensive tactics

The Federal Reserve System Law Enforcement Training Manual requires that course instructors read and sign the Instructor Performance and Expectations Acknowledgement form prior to the delivery of any basic or in-service training to acknowledge that they understood their duties and responsibilities as an instructor. The form should be maintained in the instructor’s professional file. However, upon our review of instructor’s files, we did not find evidence of forms for the following:

  • four of the nine instructors who taught courses in 2010, of which three also taught courses in 2011
  • all nine instructors who taught courses in 2012

We discussed our concerns with the Deputy Chief of the Training Bureau, who stated that he was unclear about the documentation requirements for course instructors.

Officers Did Not Complete Certain Training Requirements

We compared course schedules from 2010 through 2012 with the Federal Reserve System Law Enforcement Training Manual and reviewed training records for a sample of 50 officers: 30 who were hired prior to 2010 and 20 hired during the two-year period ending December 2012. We found that none of the officers in our sample completed the required Basic Tactics course during in-service training in 2012 because the Training Bureau did not offer the course. In addition, some officers did not meet other training requirements, as follows:

  • One of the 50 officers did not complete the annual in-service Report Writing course in 2010. In 2012, the officer was promoted to a new position that does not include the Report Writing course as a training requirement.
  • In 2012, one officer did not complete the Emergency Medical Response course. The officer’s 2010 CPR/AED certification expired in April 2012. The Training Bureau Administrative Section Commander informed us that he planned to recertify all officers in CPR/AED in 2013.

According to the Federal Reserve System Law Enforcement Training Manual, officers are required to complete all in-service courses each year to maintain their law enforcement officer designations. We discussed the Basic Tactics requirement with the Deputy Chief of the Training Bureau, who stated that he was unaware of the 2012 Federal Reserve System Law Enforcement Training Manual requirement to offer Basic Tactics and the requirement’s effective date. The Deputy Chief said he would add the mandatory Basic Tactics course to the 2013 in-service training schedule.

In addition, we noted that all officers qualified on semiautomatic pistols on a semiannual basis; however, we found that three officers in our sample did not attempt to qualify on the submachine gun on a semiannual basis during certain periods from 2010 to 2012 as required by the General Orders. According to the General Orders, the LEU adopted as its minimum standard a semiannual firearms qualification schedule for both the semiautomatic pistol and submachine gun. The LEU should administer training and retraining standards that ensure that officers are proficient in the use of all types of firearms.

We discussed the findings with the Training Section Commander, who stated that the officers likely did not qualify on the submachine guns because they had limited time at the firing range. The Deputy Chief of Operations Support stated that when officers do not qualify on the submachine guns, they are restricted from accessing them.


We recommend that the Chief of the LEU

  1. Require periodic reviews of training records to ensure that instructors and officers comply with all training and recertification requirements contained in the Federal Reserve System Law Enforcement Training Manual.
  2. Ensure that a signed Instructor Performance and Expectations Acknowledgement form is obtained annually from instructors and retained by the Training Bureau.

Management’s Response

The Director of the Management Division concurred with recommendations 8 and 9. In his response, the Director stated that controls are being strengthened for the retention of training forms for both instructors and officers, to include an annual review for all required documents. In addition, training forms are being modified as part of this effort, and a new form has been developed to capture each officer’s participation in required training topics; the new form must be signed, maintained electronically, and reviewed for compliance annually. Management’s full response is included as appendix B.

OIG Comment

In our opinion, the actions described by the Director of the Management Division address our recommendations. We plan to follow up on actions taken by the LEU to ensure that our recommendations are fully addressed.

  • 3. High-liability topics include firearms; intermediate weapons; emergency medical response; and physical control techniques, such as defensive tactics.  Return to text