Opportunities Exist for the CFPB to Strengthen Compliance with Its Purchase Card Policies and Procedures

Direct the approving officials to ensure that cardholders

1. maintain appropriate supporting documentation in their purchase card files.
2. use convenience checks as a last resort and, if used, document the reason in their convenience check logs.
3. document the reason for any purchases that may have an appearance of a split transaction.

1. expands the quarterly compliance audit to include review of receipts, invoices, and payment of taxes.
2. assesses the effectiveness of the recently implemented exit procedures for separating cardholders, including the exit checklist and related system, and makes adjustments as necessary.
3. uses available reports from the Citibank Custom Reporting System as appropriate.