OIG Auditof the Federal Trade Commission’sFinancial Statements for Fiscal Year 2017Management LetterReport No. AR 18-02A // December 2017
UNITED STATES OF AMERICAFEDERAL TRADE COMMISSIONWASHINGTON, D.C. 20580Office of Inspector GeneralDecember 21, 2017MEMORANDUMTO:Maureen K. Ohlhausen, Acting ChairmanTerrell McSweeny, CommissionerFROM: Roslyn A. MazerInspector GeneralSUBJECT: Transmittal of the Management Letter for the Fiscal Year 2017 Financial Statement AuditOn November 13, 2017, we issued to you the financial statement audit performed by the independentaccounting firm of Brown & Company CPAs, PLLC. The auditors issued an unmodified (clean) opinionon the FTC’s Fiscal Year (FY) FY 2017 financial statements.When performing an audit of an agency’s major financial systems and accounting processes, auditorsoften detect certain matters involving internal controls that do not rise to a level of seriousness to bereflected in the auditor’s opinion report. These findings are communicated in a management letter. Thismemorandum transmits a copy of the FY 2017 Financial Statement Management Letter dated December18, 2017, that reports on such matters. This letter does not affect the auditors’ unmodified opinion on thefinancial statements.The FTC has addressed all of the open recommendations from prior financial statement audits. At thebeginning of the FY 2017 financial statement audit, there were two recommendations to improve theFTC’s financial operations and internal controls. In the course of performing the FY 2017 financialstatement audit, Brown & Company identified actions the FTC took to address all of the matterspreviously identified.This letter contains one new recommendation that warrants management’s consideration. Managementconcurred with this recommendation and is in the process of implementing actions to address the issueidentified. Management’s response is reprinted in its entirety as Appendix C.
Brown & Company CPAs, PLLC is responsible for the attached Management Letter dated December 18,2017, and the conclusions expressed in the letter. We do not express opinions on the FTC’s financialstatements, nor do we provide conclusions on internal control or compliance with laws, regulations, andcontracts tested.In accordance with the Inspector General Act of 1978, as amended, we are providing copies of this letterto congressional committees with oversight and appropriation responsibilities over the FTC. In addition,we will post the report on our public website.We appreciate the cooperation afforded by management to Brown & Company and my office during theaudit. Should you have any questions or would like to discuss the report, please contact me or OIG AuditManager Mary Harmison at (202) 326-3527.Enclosure
Report DistributionFederal Trade CommissionSvetlana Gans, Chief of StaffDavid B. Robbins, Executive DirectorPatricia Bak, Deputy Executive DirectorMonique Fortenberry, Deputy Executive DirectorDavid Rebich, Chief Financial OfficerJoseph D. Oleska, Jr., Deputy Chief Financial OfficerKathryn Gillis, Assistant CFO for Financial OperationsRandy Salzer, Assistant CFO, Financial Systems and Reporting DivisionTonia Hill, Internal Control/Risk Management Program LeadFTC Appropriations and Authorizing CommitteesUnited States House Judiciary CommitteeThe Honorable Bob Goodlatte, ChairmanThe Honorable Jerrold Nadler, Ranking Member38 Rayburn House Office BuildingWashington, DC 20515(202) 225-3951Majority contact Ryan.firstname.lastname@example.orgMinority contact Slade.email@example.comUnited States House Energy and Commerce CommitteeThe Honorable Greg Walden, ChairmanThe Honorable Frank Pallone, Jr., Ranking Member2125 Rayburn House Office BuildingWashington, DC 20515(202) 225-2927Majority contact firstname.lastname@example.orgMinority contact email@example.comUnited States House Appropriations CommitteeThe Honorable Rodney Frelinghuysen, ChairmanThe Honorable Nita Lowey, Ranking MemberH-305The CapitolWashington, DC 20515202-225-2771Majority contact Kelly.firstname.lastname@example.orgMinority contact Lisa.Molyneux@mail.house.gov
United States Senate Judiciary CommitteeThe Honorable Charles E. Grassley, ChairmanThe Honorable Dianne Feinstein, Ranking Member224 Dirksen Senate Office BuildingU.S. SenateWashington, DC 20510202-224-5225Majority contact Phil Alito@judiciary-rep.senate.govMinority contact michael email@example.comUnited States Senate Commerce CommitteeThe Honorable John Thune, ChairmanThe Honorable Bill Nelson, Ranking MemberCommittee on Commerce, Science, & Transportation152 Dirksen Senate Office BuildingU.S. SenateWashington, DC 20510202-224-1251Majority contact Peter firstname.lastname@example.orgMinority contact christian email@example.comUnited States Senate Appropriations CommitteeThe Honorable Thad Cochran, ChairmanThe Honorable Patrick Leahy, Vice ChairmanCommittee on AppropriationsRoom S-128The CapitolWashington, DC 20510202-224-7257Majority contact taylor firstname.lastname@example.orgMinority contact emily email@example.com
FEDERAL TRADE COMMISSIONMANAGEMENT LETTERFOR THE YEAR ENDEDSEPTEMBER 30, 2017
FEDERAL TRADE COMMISSIONSEPTEMBER 30, 2017FY 2017 MANAGEMENT LETTER COMMENTSTABLE OF CONTENTSTransmittal Letter.1Appendix A – Management Letter Comments .2Finding 2017-01: Employee Debt Receivables Over 120 Days For Which FTCFinancial Management Operations Had Taken No Recent Follow-Up Action .2Appendix B – Status of Prior Years Recommendations .4Appendix C – Management’s Response .5
December 18, 2017Federal Trade CommissionWashington, D.C.To: Management and the Commissioners of the Federal Trade CommissionIn planning and performing our audit of the financial statements of the Federal Trade Commission(FTC) as of and for the year ended September 30, 2017, on which we have issued our report datedNovember 13, 2017, in accordance with auditing standards generally accepted in the United Statesof America, we considered FTC’s internal control over financial reporting as a basis for designingaudit procedures that are appropriate in the circumstances but not for the purpose of expressing anopinion on the effectiveness of FTC’s internal control. Accordingly, we do not express an opinionon the effectiveness of FTC’s internal control. This report is based on our knowledge as of the dateof our report on the financial statements, obtained in performing our audit thereof, and should beread with that understanding.Our consideration of internal control was for the limited purpose described in the precedingparagraph and was not designed to identify all deficiencies in internal control. However, duringthe audit, we noted certain matters involving the internal control and other operating matters thatare presented for your consideration. This letter does not affect our report dated November 13,2017 on the financial statements. The management letter comments are summarized in AppendixA. The status of prior year recommendations is presented in Appendix B. Although we haveincluded management’s written response to our comments in Appendix C, such responses have notbeen subjected to the auditing procedures applied in our audit of the financial statements and,accordingly, we do not express an opinion or provide any form of assurance on the appropriatenessof the response or the effectiveness of any corrective actions described therein.This communication is intended solely for the information and use of the management of FTC,OMB, OIG and the U.S. Congress, and is not intended to be and should not be used by anyoneother than these specified parties.Very truly yours,Largo, Maryland1 Page
APPENDIX AFEDERAL TRADE COMMISSIONSEPTEMBER 30, 2017FY 2017 MANAGEMENT LETTER COMMENTFinding 2017-01:Employee Debt Receivables Over 120 Days Old For Which FTCFinancial Management Operations Had Taken No Recent Follow-UpAction.Condition:FTC Financial Management Operations has taken or plans to take to ensure the employeedebt receivables are valid and accurate. However, the lack of aggressive action to collectoutstanding employee debts or follow-up action has led to employee debt receivables over120 days old. During our interim substantive testing, we randomly select seven (7)transactions for testing. We noted the receivables outstanding on June 30th for separatedemployees were substantially past due, increasing the likelihood that they would not becollected in full. FTC Financial Management Operations were generally not collectingreceivables for separated employees as aggressively due to lack of Agency policies andprocedures. They were not periodically contacting the debtors or regularly evaluating thedebts to determine collection action needed.In addition, FTC Financial Management Operations did not compute and record additionalcharges correctly for delinquent receivables associated with separated employees. TheDebt Collection Act of 1982 or the Federal Claims Collections Standards generally allowthe Agency to collect interest and handling charges and penalties where the debtor doesnot promptly pay its bills. These additional charges were not accurately recorded for theseven transactions.As of June 30, 2017, the employee debt receivable balance is 81,585.34.Criteria:Federal Trade Commission 16 CFR Part 1 Administrative Debt Collection Procedures,Subpart P – Administrative Debt Collection, Including Administrative Offset, stated that“The Commission shall apply the Federal Claims Collection Standards (FCCS), 31 CFRparts 900-904, in the administrative collection, offset, compromise, suspension,termination, and referral of collection activity for civil claims for money, funds, orproperty, as defined by 31 U.S.C 3701(b), unless specific Federal agency statutes orregulations apply to such activities or, as provided by the Title 11 of the United StatesCode, when the claims involve bankruptcy. The Commission shall also follow Departmentof Treasury regulations set forth at 31 CFR part 285, as applicable, for administrative debtcollection, including centralized offset of federal payments to collect non-tax debts thatmay be owed to the Commission, 31 CFR 285.5. Nothing in this subpart shall be construedto supersede or require the Commission to provide additional notice or other proceduresthat may have already been provided or afforded to a debtor in the course of administrativeor judicial litigation or otherwise”.2 Page
Office of Management and Budget (OMB) Circular A-123, Management’s Responsibilityfor Enterprise Risk Management and Internal Control, requires management to beresponsible for establishing and maintaining internal controls to achieve the objectives ofeffective and efficient operations, reliable financial reporting and compliance withapplicable laws and regulations.Cause:The agency lacks policies and procedures which made it difficult to take action to collectoutstanding employee debt. In addition, resource limitations was also a factor for notregularly recording additional charges. The computations needed, as well as the relatedaccounting entries, were many and time consuming to perform. Also, locate documentationsupporting the validity of the outstanding employee debt receivables is a challenge.Effect:Employee debt receivables balance could be understated or overstated.Recommendations:We recommend that the Chief Financial Officer:a. Ensure the FTC finalizes Agency policies and procedures regarding employeedebt receivables.b. Evaluate the outstanding employee debt receivables and make a decision tocollect or refer to Treasury for collections.c. Generate demand letters for Agency identified collection initiatives.d. Make a decision on how to compute and record additional charges.3 Page
APPENDIX BFEDERAL TRADE COMMISSIONSEPTEMBER 30, 2017STATUS OF PRIOR YEARS RECOMMENDATIONSReport Reference2016-01Improved Accounting andControls are Needed OverDisbursements2016-02Improved Accounting and Controls areNeeded Over Interest Receivables4 PageDescriptionRecommendationDuring our testing of disbursements in fiscal year2016, we identified errors in 1 of 77 samples.Specifically, we noted the following:1. The invoice number 1021715 in the amount of 264,719.76 did not clearly define the ContractLine Item Numbers (CLINs) to be billed forservices.2. The CLINs on the related receiving report signedby the COR did not agree with invoice.3. The CLINs entered in Oracle for disbursementdid not agree with invoice or receiving report.We recommend FTC managementimplement written procedures to ensureinvoice will not be processedfor payment unless is it properlyinvoiced, accurate, and in compliancewith contract terms.Although FTC had implemented a process forcalculating the interest receivable for redressjudgements, the agency did not estimate and reportinterest receivable of 408,627.00 as of June30, 2016. The initial testing of the interest receivablebalance as of June 30, 2016 ( 405,609.56) led to thediscovery of a calculation error in one sample thatwas selected from a population of 29 matters. Theresult was an increase in the overall calculatedbalance.We recommend FTC FinancialManagement Operations follow andimprove the approved process policy andprocedures to ensure that the interestreceivable balance is reconciledquarterly.Status as ofSeptember 30, 2017Closed.We recommend FTC management ensureany changes to the receiving report areclearly documented priorto processing disbursement for payment.Closed.
APPENDIX CFEDERAL TRADE COMMISSIONSEPTEMBER 30, 2017MANAGEMENT’S RESPONSE5 Page
United States Senate Judiciary Committee The Honorable Charles E. Grassley, Chairman The Honorable Dianne Feinstein, Ranking Member 224 Dirksen Senate Office Building U.S. Senate Washington, DC 20510 202-224-5225 Majority contact Phil_Alito@judiciary-rep.senate.gov Minority contact firstname.lastname@example.org
Former VP of Sales for Defendant Alliance Security Inc. FTC-0000219 : FTC-0000231 : 23 : Transcript of Deposition of Defendant Jasjit Gotra, CEO of Defendant Defendant Alliance Security Inc. FTC-0000232 ; FTC-0000261 : 24 ; Transcript of Deposition of Justin Ramsey, former Lead Generator and Telemarketer for Defendant Alliance Security Inc. FTC .
Kettering FTC Workshop EW - 2015 FTC –JAVA PROGRAMMING Workshop 2015 Eric Weber FRC: 1322, FTC: 5954 & 7032
The FTC and the Law Firm agreed to speak. again on June 20, 20 II. During those conversations and in a subsequent letter from the FTC on June 21, 20 II, the FTC failed to show (or even articulate) good cause as to why it needs this informatIon from the Law Firm as required by the FTC administrative rules and common law principles favoring the
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