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To accomplish our objectives, we reviewed the CFPB's Policy for Conference/Meeting Planning and Attendance and Non-Academic External Training and Education Policy to identify risks and corresponding controls. To gain detailed knowledge of the CFPB's current conference activities, we interviewed members of the CFO Internal Review Team and staff in the Offices of Procurement and External Affairs. We also interviewed staff in Treasury DO and BPD ARC who are authorized to coordinate conference activities on the CFPB's behalf. We performed detailed transaction testing to assess the effectiveness and consistency of controls as well as compliance with policies and procedures.
The scope of our evaluation included conference activities that occurred from January 1, 2011, to September 30, 2012. We obtained conference contracts and supporting documentation for conferences procured through BPD ARC, Treasury DO, and Office of Procurement. We also obtained purchase card transactions and supporting bank statements, for conferences that were sponsored by the CFPB as well as nonsponsored conferences attended by CFPB employees. Additionally, we obtained SF-182 forms completed during the scope of our evaluation.8
We judgmentally selected samples for detailed testing based on cost, location, and date. Policies and procedures were used as criteria for detailed testing. Because our sample included conferences that occurred before policy implementation, we also used informal practices as criteria. In selecting the sample, we included conferences that occurred before and after the implementation of the conference and training policies and procedures. We tested conferences from each acquisition approach for documentation supporting authorized purchases and appropriate spending limits. Additionally, we tested SF-182 forms for appropriate approvals and conference justification. We did not identify any material discrepancies related to these areas.
We conducted our fieldwork from October 2012 through April 2013. We compiled the population for the January 1, 2011, through September 30, 2012, time frame from information provided by the CFPB. As previously mentioned, we could not conduct completeness testing to confirm the number of conferences and the corresponding amounts reported by the CFPB because the agency does not have a central tracking mechanism. For additional information regarding our sample selection, see appendix B.
We conducted our evaluation in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.