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The Office of Inspector General (OIG) conducted an evaluation of the Consumer Financial Protection Bureau's (CFPB's) conference activities. Our objectives were to (1) determine the CFPB's management controls, including its policies, procedures, and practices associated with the agency's sponsored and nonsponsored conferences,1 and (2) assess whether the CFPB's conference expenses and practices followed applicable policies and procedures.
We initiated this evaluation, in part, to determine whether the facts, circumstances, and findings of the General Services Administration (GSA) OIG's 2010 Western Regions Conference investigation report, issued on April 2, 2012, had also occurred at the CFPB.2 Upon initiating our evaluation, we learned that the CFPB's Chief Financial Officer (CFO), in response to the GSA OIG's report, had formed the CFO Internal Review Team to assess the CFPB's compliance with internal controls over conference-related activities and meetings. As a result, we designed our evaluation to minimize any duplication of effort by focusing on the CFPB's newly created policies and procedures that resulted, in part, from the CFO Internal Review Team's efforts.
To accomplish our objectives, we reviewed the CFPB's Policy for Conference/Meeting Planning and Attendance and Non-Academic External Training and Education Policy, and we interviewed members of the CFO Internal Review Team and staff in the Offices of Procurement and External Affairs. We also interviewed staff of the Department of the Treasury Departmental Offices (Treasury DO) and the Bureau of Public Debt's Administrative Resource Center (BPD ARC) who were involved in coordinating conference activities on the CFPB's behalf. We conducted testing to assess the effectiveness of the controls and compliance with policies and procedures. The scope of our audit was from January 1, 2011, through September 30, 2012, and included 144 conferences totaling $397,724.3 For additional information regarding our scope and methodology, see appendixes A and B.
Section 1066 of the Dodd-Frank Wall Street Reform and Consumer Protection Act authorized the CFPB to operate under authorities granted to the Secretary of the Treasury until the confirmation of the Director of the CFPB. The CFPB established two agreements with the Department of the Treasury to provide administrative services, including conference-related support.4 The agency executed its agreement with BPD ARC, which covers various administrative services including procurement and event service support, on November 21, 2011, and its agreement with the Treasury DO on December 2, 2011. These are the two external approaches through which the CFPB coordinates conference activities. In addition, the CFPB has two internal approaches to coordinating conferences: the Office of Procurement and CFPB offices' use of agency-issued purchase cards.
The CFPB began drafting a conference memorandum in November 2011. After receiving input from CFPB managers, the draft memorandum was forwarded to the Chief Operating Officer in January 2012. The CFPB incorporated this memorandum into policy and conducted a Chief Operating Officer review and comment process during the second quarter of 2012. As a result, the CFPB implemented the Policy for Conference/Meeting Planning and Attendance on May 22, 2012. This policy, which incorporates associated procedures, covers both agency-sponsored and nonsponsored conference activities. According to the policy, agency-sponsored conferences are coordinated through Treasury DO or the Office of Procurement and nonsponsored conferences attended by CFPB staff are coordinated through the Office of Procurement or use of purchase cards by CFPB offices.
On May 11, 2012, the agency implemented its Non-Academic External Training and Education Policy, which covers the policy and procedures for attendance at external conferences and trainings. Among other things, this policy requires that external training (1) be related to an employee's official duties, (2) address an identified developmental need for the employee, and (3) not be available internally. This policy also outlines covered expenses, reimbursement guidelines, continued service agreements, and approval authorities. Both the Non-Academic External Training and Education Policy and the Policy for Conference/Meeting Planning and Attendance require that CFPB employees complete an SF-182 form5 for nonsponsored conferences and external training courses.
After the release of the April 2012 GSA OIG's report, the CFO Internal Review Team conducted a review of conference activities and meetings that took place prior to the implementation of the CFPB's May 2012 policies and procedures. The purpose of this review was to assess the CFPB's internal controls over conference-related activities. During its review, the CFO Internal Review Team identified four acquisition approaches used by the CFPB to coordinate conferences. The review assessed conference travel and costs, such as room rentals, meals, and incidentals, incurred from July 21, 2011, through May 31, 2012.
On September 5, 2012, the CFO Internal Review Team issued an internal report detailing the results of this review.6 The report included six suggested actions related to compliance with CFPB policies and procedures to improve the efficiency and effectiveness of operations and enhance internal controls. The CFPB indicated to us that it is implementing the recommended actions. We did not assess the agency's progress in implementing the recommended actions as part of our evaluation.7
After the CFO's internal review, CFPB management requested that employees who attended conferences and external training from July 21, 2011, through May 22, 2012, retroactively complete SF-182 forms and provide acceptable proof of completion for recordkeeping purposes. During our evaluation, we observed that employees are responding to this request.