H.R. 1495
Gold Reserve Transparency Act of 2011 Gao ID: GAO-11-768T June 23, 2011This testimony discusses H.R. 1495, the Gold Reserve Transparency Act of 2011. This proposed legislation, which was recently referred to the Subcommittee on Domestic Monetary Policy and Technology, House Committee on Financial Services, provides for an audit of the gold reserves of the United States. Specifically, the bill calls for the Secretary of the Treasury to conduct and complete, not later than 6 months after passage of the act, a full assay, inventory, and audit of gold reserves of the United States at the place or places where such reserves are kept, together with an analysis of the sufficiency of the measures taken for the security of such reserves. The bill also calls for the Government Accountability Office (GAO) to review the results of such assay, inventory, audit, and analysis and, not later than 9 months after passage of the act, prepare and transmit to the Congress a report of GAO's findings together with the results of the work performed by the Secretary of the Treasury. This testimony focuses on (1) the reported holdings of gold reserves of the United States as of September 30, 2010; (2) past and current audit efforts regarding gold reserves of the United States, including those of the Department of the Treasury's (Treasury) Office of Inspector General (OIG); and (3) the requirements of H.R. 1495.
The holdings of gold reserves of the United States are presented in various financial reports, including the United States Mint's (Mint) Schedule of Custodial Deep Storage Gold and Silver Reserves (Mint's Custodial Schedule), the Mint's financial statements, and Treasury's departmentwide financial statements. As of September 30, 2010, most, or approximately 95 percent, of the reported gold reserves of the United States were in the custody of the Mint. The gold reserves in the custody of the Mint are comprised of deep storage and working stock gold. Deep storage gold, which consists primarily of gold bars, represented nearly all of the gold reserves in the custody of the Mint and was maintained in three locations: the United States Bullion Depository at Fort Knox, Kentucky; the Mint at Denver, Colorado; and the Mint at West Point, New York. Working stock--which consists of bars, blanks, unsold coins, and condemned coins--represented about 1 percent of the reported gold reserves in the custody of the Mint and can be used as the raw material for minting coins. The remaining reported holdings of gold reserves of the United States were in the custody of the Federal Reserve Bank of New York. In 1974, in response to congressional interest and in conjunction with the Mint, GAO assisted in the planning and observed the inventory of gold reserves of the United States maintained by the United States Bullion Depository at Fort Knox. GAO selected 3 of the 13 compartments at this depository to be audited. The audit procedures included observing and participating in a physical inventory of the entire contents of the three compartments. GAO did not report any differences between the gold stored in these compartments and the Fort Knox depository's records. In addition, GAO's procedures included observing the assaying of a sample of gold bars. The results of the assays indicated that the recorded finenesses were within the tolerances the Mint established. In connection with this audit, GAO recommended that the Secretary of the Treasury request the Director of the Mint to annually perform a cyclical inventory of its gold holdings to ensure that the gold holdings in all compartments would be inventoried over a specified period of years. Acting on this recommendation, Treasury established the Committee for Continuing Audits of United States Government-owned Gold (Committee for Continuing Audits) in 1975 to oversee and provide guidelines and general direction for continuing audits.5 The objectives of the continuing audits were to verify the accuracy of the inventory of gold and the adequacy of related accounting records and internal controls in accordance with Treasury audit policies. H.R. 1495 provides for the Secretary of the Treasury to conduct and complete a full assay, inventory, and audit of gold reserves of the United States and an analysis of the sufficiency of the measures taken for the security of such reserves. In considering the provisions of H.R. 1495, it will be important to consider the cost, benefit, and timing of actions needed to implement the proposed requirements. H.R. 1495, if enacted, may result in duplication of certain past and current efforts, especially with regard to inventorying and auditing the gold reserves of the United States. Nevertheless, GAO would be capable of carrying out the required review of the results of the Secretary of the Treasury's actions called for by the bill, should it be enacted. GAO's review would include visits to the facilities at which the gold reserves of the United States are held to selectively observe the inventorying and auditing of the gold reserves and xaminations of various documentation supporting the required assay, inventory, and audit.
GAO-11-768T, H.R. 1495: Gold Reserve Transparency Act of 2011
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United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Domestic Monetary Policy and Technology,
House Committee on Financial Services:
For Release on Delivery:
Expected at 2:00 p.m. EDT:
Thursday, June 23, 2011:
H.R. 1495:
Gold Reserve Transparency Act of 2011:
Statement of Gary T. Engel:
Director Financial Management and Assurance:
GAO-11-768T:
Mr. Chairman, Ranking Member Clay, and Other Members of the
Subcommittee:
I am pleased to be here today to discuss H.R. 1495,[Footnote 1] the
Gold Reserve Transparency Act of 2011. This proposed legislation,
which was recently referred to your Subcommittee, provides for an
audit of the gold reserves of the United States. Specifically, the
bill calls for the Secretary of the Treasury to conduct and complete,
not later than 6 months after passage of the act, a full assay,
[Footnote 2] inventory, and audit of gold reserves of the United
States at the place or places where such reserves are kept, together
with an analysis of the sufficiency of the measures taken for the
security of such reserves. The bill also calls for the Government
Accountability Office (GAO) to review the results of such assay,
inventory, audit, and analysis and, not later than 9 months after
passage of the act, prepare and transmit to the Congress a report of
GAO's findings together with the results of the work performed by the
Secretary of the Treasury.
My testimony today will focus on (1) the reported holdings of gold
reserves of the United States as of September 30, 2010; (2) past and
current audit efforts regarding gold reserves of the United States,
including those of the Department of the Treasury's (Treasury) Office
of Inspector General (OIG); and (3) the requirements of H.R. 1495.
We conducted our work from June 3, 2011, to June 21, 2011, in
accordance with all sections of GAO's Quality Assurance Framework that
are relevant to our objectives. The framework requires that we plan
and perform the engagement to obtain sufficient and appropriate
evidence to meet our stated objectives and to discuss any limitations
in our work. We believe that the information and data obtained, and
the analysis conducted, provide a reasonable basis for any findings
and conclusions in this product.
Gold Reserves of the United States:
The holdings of gold reserves of the United States are presented in
various financial reports, including the United States Mint's (Mint)
Schedule of Custodial Deep Storage Gold and Silver Reserves (Mint's
Custodial Schedule), the Mint's financial statements, and Treasury's
departmentwide financial statements. As of September 30, 2010, most,
or approximately 95 percent, of the reported gold reserves of the
United States were in the custody of the Mint. The gold reserves in
the custody of the Mint are comprised of deep storage and working
stock gold. Deep storage gold, which consists primarily of gold bars,
represented nearly all of the gold reserves in the custody of the Mint
and was maintained in three locations: the United States Bullion
Depository at Fort Knox, Kentucky; the Mint at Denver, Colorado; and
the Mint at West Point, New York. Working stock--which consists of
bars, blanks, unsold coins, and condemned coins--represented about 1
percent of the reported gold reserves in the custody of the Mint and
can be used as the raw material for minting coins. The remaining
reported holdings of gold reserves of the United States were in the
custody of the Federal Reserve Bank of New York. Table 1 presents the
reported amounts as of September 30, 2010, of fine troy ounces (FTOs)
[Footnote 3] of gold reserves of the United States by category and the
financial reports in which such categories were presented. From
September 30, 2006, through September 30, 2010, the reported fiscal
year-end amounts of FTOs of (1) deep storage gold reserves in the
custody of the Mint and (2) gold reserves in the custody of the
Federal Reserve Bank of New York have not changed.
Table 1: Gold Reserves of the United States as of September 30, 2010:
Gold reserves in the custody of the Mint: Deep storage;
FTOs: 245,262,897;
Treasury's Departmentwide Financial Statements: [Empty];
Mint's Financial Statements: [Check];
Mint's Custodial Schedule: [Check].
Gold reserves in the custody of the Mint: Working stock;
FTOs: 2,783,219;
Treasury's Departmentwide Financial Statements: [Empty];
Mint's Financial Statements: [Check];
Mint's Custodial Schedule: [Empty].
Total gold reserves in the custody of the Mint:
FTOs: 248,046,116;
Treasury's Departmentwide Financial Statements: [Check];
Mint's Financial Statements: [Empty];
Mint's Custodial Schedule: [Empty].
Gold reserves in the custody of the Federal Reserve Bank of New York:
FTOs: 13,452,784;
Treasury's Departmentwide Financial Statements: [Check];
Mint's Financial Statements: [Empty];
Mint's Custodial Schedule: [Empty].
Total gold reserves of the United States:
FTOs: 261,498,900;
Treasury's Departmentwide Financial Statements: [Empty];
Mint's Financial Statements: [Empty];
Mint's Custodial Schedule: [Empty].
Source: GAO analysis of Treasury financial reports.
[End of table]
Past and Current Audit Efforts Regarding Gold Reserves of the United
States:
In 1974, in response to congressional interest and in conjunction with
the Mint, GAO assisted in the planning and observed the inventory of
gold reserves of the United States maintained by the United States
Bullion Depository at Fort Knox.[Footnote 4] GAO selected 3 of the 13
compartments at this depository to be audited. The audit procedures
included observing and participating in a physical inventory of the
entire contents of the three compartments. GAO did not report any
differences between the gold stored in these compartments and the Fort
Knox depository's records. In addition, GAO's procedures included
observing the assaying of a sample of gold bars. The results of the
assays indicated that the recorded finenesses were within the
tolerances the Mint established.
In connection with this audit, GAO recommended that the Secretary of
the Treasury request the Director of the Mint to annually perform a
cyclical inventory of its gold holdings to ensure that the gold
holdings in all compartments would be inventoried over a specified
period of years. Acting on this recommendation, Treasury established
the Committee for Continuing Audits of United States Government-owned
Gold (Committee for Continuing Audits) in 1975 to oversee and provide
guidelines and general direction for continuing audits.[Footnote 5]
The objectives of the continuing audits were to verify the accuracy of
the inventory of gold and the adequacy of related accounting records
and internal controls in accordance with Treasury audit policies. A
March 1982 report to the Congress by the Gold Commission[Footnote 6]
noted that the continuing audit of such gold was conducted on a
cyclical basis because of the enormous quantity of gold to be handled
and the related costs.[Footnote 7] In an April 1987 report on
continuing audits of the United States government-owned gold,[Footnote
8] the Treasury OIG stated that the continuing audits were designed to
ensure that about 10 percent of the United States government-owned
gold was audited annually.[Footnote 9] Further, the Treasury OIG
stated that on September 19, 1986, the Inspector General had
recommended canceling Treasury Department Order No. 234-1, which had
resulted in the creation of the Committee for Continuing Audits,
because it was unnecessary in view of the authority of the Inspector
General to conduct audits of the gold stock under other Treasury
Orders. It was also stated that annual audits of government-owned gold
were no longer necessary because (1) virtually all of the gold in the
custody of the Mint had been audited and placed under seal and (2)
there had been essentially no discrepancies found as a result of those
audits. Moreover, it was noted that Treasury Department Order No. 234-
1 was subsequently canceled. According to the Treasury OIG, about 92
percent of the United States government-owned gold had been audited by
either GAO[Footnote 10] or the Committee for Continuing Audits as of
September 30, 1986.
More recently, the gold reserves of the United States have been
presented in various financial reports and have therefore been subject
to various audit efforts. For example, while the deep storage gold
reserves are a primary focus of the audit of the Mint's Custodial
Schedule, which is audited by the Treasury OIG, the deep storage gold
reserves are also within the scope of the audit of the Mint's
financial statements, which are audited by independent public
accountants. Also, as a bureau within Treasury, the balances and
activity of the Mint are included on Treasury's departmentwide
financial statements, which are required by law to annually be
prepared, audited, and submitted to the Congress and the Director of
the Office of Management and Budget. Specifically, 31 U.S.C. §3515(b)
requires that the financial statements of covered executive agencies,
of which Treasury is one, include the overall financial position of
the offices, bureaus, and activities covered by the statements,
including the assets and liabilities thereof; and the results of
operations of those offices, bureaus, and activities.
Treasury OIG's Audits of Gold Reserves in the Custody of the Mint:
The Inspector General Act of 1978, as amended,[Footnote 11] (IG Act)
created offices of inspector general at major federal departments,
including the Treasury OIG,[Footnote 12] to provide independent audits
and investigations; promote economy, efficiency, and effectiveness;
and prevent and detect fraud, waste, and abuse in the respective
department's programs and operations.[Footnote 13] The Treasury OIG
performs annual audits of the Mint's Custodial Schedule,[Footnote 14]
which reports the deep storage gold reserves. As shown in table 1, the
deep storage gold reserves represent nearly all of the gold reserves
in the custody of the Mint.
Since issuing its first audit report on the Mint's Custodial Schedules
in 1995, which presented the results of its audit of the Mint's
Custodial Schedules as of September 30, 1994, and 1993, the Treasury
OIG has annually audited the deep storage gold reserves in the custody
of the Mint as reported in the respective Mint's Custodial Schedules.
For each of the fiscal years under audit, the Treasury OIG rendered
unqualified or "clean" opinions on the Mint's Custodial Schedules. In
addition, the Treasury OIG did not report any material weaknesses
[Footnote 15] in internal control over financial reporting relating to
the schedules for these fiscal years. The Treasury OIG's most recent
audit report on the Mint's Custodial Schedules, which presented the
deep storage gold reserves in the custody of the Mint as of September
30, 2010, was issued on October 21, 2010.
In connection with the Treasury OIG's annual audits of the Mint's
Custodial Schedules, Treasury OIG officials told us that the Treasury
OIG reviews the physical controls (e.g., security fences, armed
guards, security cameras, metal detectors) at each of the three Mint
locations where the deep storage gold reserves are maintained.
According to Treasury OIG officials, as of September 30, 2010, there
were 42 compartments of deep storage gold reserves spread among these
three Mint locations. As previously noted, Treasury OIG officials
estimate that about 92 percent of the United States government-owned
gold was audited by either GAO or the Committee for Continuing Audits
as of September 30, 1986. These officials told us that once the
inventory of a compartment being audited was completed, the
compartment was sealed with an official joint seal. A joint seal is
intended to place the gold contained in a compartment under such
control that subsequent representatives can accept the verification
made by previous representatives as to the weight and count of the
gold. According to Treasury OIG officials, the official joint seals,
for all of the compartments that were audited by either GAO or the
committee and that had not been opened since such audits, were
inspected by the Treasury OIG, as part of its audits of the Mint's
Custodial Schedules, to verify that the seals had not been
compromised. These officials also told us that over the course of the
Treasury OIG's audits of the Mint's Custodial Schedules for fiscal
years 1993 through 2008, the compartments containing the deep storage
gold reserves not audited by either GAO or the committee, along with
any previously sealed compartments that were opened, were selected and
audited. These officials told us that such audits included verifying
the following to the Mint's inventory records:
1. the number of gold bars in each melt;
2. the melt number for each gold bar in the melt; and:
3. the fineness stamped on each gold bar in the melt.
In addition, as part of the audits of the selected compartments,
Treasury OIG officials stated that the Treasury OIG's audit procedures
have included selecting a statistical sample of gold bars from the
selected compartments to be weighed and assayed and that no material
differences were noted. These officials also told us that once the
inventory of a selected compartment being audited was completed, the
compartment was sealed with an official joint seal to control the gold
reserves contained in the compartment. According to Treasury OIG
officials, opening and sealing compartments require the presence of
three individuals--a representative of the facility where the gold
reserves are held, a representative of the Director of the Mint, and a
representative of the Treasury OIG. They also told us that, as of the
end of fiscal year 2008, an inventory of each of the 42 compartments
had been observed either by GAO, the Committee for Continuing Audits,
or the Treasury OIG and that there has been no movement of deep
storage gold reserves since that time. As such, in addition to
considering internal control over financial reporting related to the
Mint's Custodial Schedules, Treasury OIG officials stated that the
Treasury OIG's audit procedures since fiscal year 2008 have primarily
focused on inspecting the official joint seals each year for all 42
compartments to verify that they had not been compromised.
Independent Public Accountants' Audits Covering Gold Reserves in the
Custody of the Federal Reserve Bank of New York and the Mint:
The gold reserves of the United States on Treasury's departmentwide
financial statements consist of the gold reserves in the custody of
the Mint and those in the custody of the Federal Reserve Bank of New
York. Since fiscal year 2004, independent public accountants have
rendered clean opinions on these financial statements. According to
Treasury OIG officials, these independent public accountants' primary
audit procedure regarding the gold reserves in the custody of the
Federal Reserve Bank of New York involves annually obtaining a
confirmation from the Federal Reserve regarding the gold reserves of
the United States that are in the Federal Reserve Bank of New York's
custody as of fiscal year-end, including the amount of FTOs. The gold
reserves in the custody of the Mint are also reported on the Mint's
annual financial statements. Independent public accountants have
rendered clean opinions on the Mint's financial statements for fiscal
years 2005 through 2010.[Footnote 16] According to Treasury OIG
officials, these independent public accountants' procedures with
regard to the deep storage gold reserves in the custody of the Mint
have included reviewing the Treasury OIG's audit documentation,
accompanying the Treasury OIG on site visits to the Mint's storage
locations, reviewing the physical controls at the locations visited,
and reperforming certain of the Treasury OIG's audit procedures.
Requirements of H.R. 1495:
H.R. 1495 provides for the Secretary of the Treasury to conduct and
complete a full assay, inventory, and audit of gold reserves of the
United States and an analysis of the sufficiency of the measures taken
for the security of such reserves. In considering the provisions of
H.R. 1495, it will be important to consider the cost, benefit, and
timing of actions needed to implement the proposed requirements. H.R.
1495, if enacted, may result in duplication of certain past and
current efforts, especially with regard to inventorying and auditing
the gold reserves of the United States. Nevertheless, GAO would be
capable of carrying out the required review of the results of the
Secretary of the Treasury's actions called for by the bill, should it
be enacted. GAO's review would include visits to the facilities at
which the gold reserves of the United States are held to selectively
observe the inventorying and auditing of the gold reserves and
examinations of various documentation supporting the required assay,
inventory, and audit.
H.R. 1495 also provides for GAO to prepare and transmit to the
Congress, not later than 9 months after enactment of the act, a report
of GAO's findings from such review together with the results of the
assay, inventory, audit, and analysis conducted by the Secretary of
the Treasury. According to Treasury officials, because of the enormous
quantity of gold that would need to be inventoried and assayed, there
is uncertainty regarding the ability of Treasury to complete such
actions within the 6-month period provided in H.R. 1495. If Treasury's
efforts are not completed within the 6-month period, there would be
limitations on the scope of GAO's work if GAO were required to report
within 9 months after enactment of the act. GAO stands ready to work
with the Subcommittee on developing changes to the provisions of H.R.
1495 that would most efficiently utilize the results of past and
current gold reserve assay, inventory, and audit efforts.
Mr. Chairman and Ranking Member Clay, this concludes my prepared
statement. I would be pleased to respond to any questions that you or
other members of the Subcommittee may have at this time.
[End of section]
Footnotes:
[1] Gold Reserve Transparency Act of 2011, H.R. 1495, 112TH Congress
(2011).
[2] To verify the fineness (the percentage of gold content at the time
of melting) of a gold bar, it is assayed. This involves analyzing a
sample from the bar to determine the quantity of gold in it.
[3] Fine troy ounces represent the gold content of the melt (that is,
the melting, pouring, and casting of metal into molds) as determined
by multiplying the melt's gross weight by its fineness.
[4] See GAO, Accountability and Physical Controls of the Gold Bullion
Reserves, Department of the Treasury, [hyperlink,
http://www.gao.gov/products/FOD-75-10] (Washington, D.C.: February
1975).
[5] This committee was created as a result of the June 3, 1975,
Department Order No. 234-1, issued by the Secretary of the Treasury
authorizing and directing the Fiscal Assistant Secretary, with the
cooperation and assistance of the Director of the Mint, to conduct a
continuing audit of the United States government-owned gold for which
the Treasury is accountable.
[6] Pursuant to Public Law 96-389, 94 Stat. 1551, 1555, § 10 (Oct. 7,
1980), the members of the Gold Commission were appointed by the
Secretary of the Treasury to conduct a study to assess and make
recommendations with regard to the policy of the U.S. government
concerning the role of gold in domestic and international systems.
[7] Report to the Congress of the Commission on the Role of Gold in
the Domestic and International Monetary Systems, Volume II, Annex D:
Continuing Audit of the United States Government-Owned Gold, March
1982.
[8] Department of the Treasury, Office of the Inspector General,
Summary Report of Continuing Audits of United States Government-owned
Gold as of September 30, 1986, OIG-87-42, (Apr. 24, 1987).
[9] In this report, the Treasury OIG stated that the Committee for
Continuing Audits was headed by the Chief of the Internal Audit Staff
of Treasury's Bureau of Government Financial Operations and included
the Chief of the Internal Audit Staff of the Mint and the Assistant
General Auditor of the Federal Reserve Bank of New York. The Treasury
OIG also stated that (1) effective October 1, 1982, the internal audit
staffs of the Bureau of Government Financial Operations and the Mint
were reorganized under the Treasury OIG, and (2) on October 10, 1984,
the Bureau of Government Financial Operations became the Financial
Management Service.
[10] Of the about 92 percent of the United States government-owned
gold that had been audited as of September 30, 1986, GAO audited
approximately 13 percent in 1974.
[11] Pub. L. No. 95-452, 92 Stat. 1101 (Oct. 12, 1978) (codified, as
amended, at 5 U.S.C. App.).
[12] The Treasury OIG was established by the Inspector General Act
Amendments of 1988 (Public Law 100-504).
[13] In accordance with the IG Act, the Treasury OIG was appointed by
the President and confirmed by the Senate, which, among other
provisions of the IG Act, allows the Treasury's OIG to perform audits
in compliance with the independence requirements of Government
Auditing Standards (See GAO, Government Auditing Standards, July 2007
Revision, [hyperlink, http://www.gao.gov/products/GAO-07-731G]
(Washington, D.C.: July 2007), issued by the Comptroller General of
the United States), 5 U.S.C. App. § 4(b).
[14] Prior to fiscal year 2000, the Mint's Custodial Schedule was
called a Statement of Custodial Gold and Silver Reserves.
Additionally, beginning in fiscal year 2006, "deep storage" was added
to the title.
[15] A material weakness is a deficiency, or a combination of
deficiencies, in internal control such that there is a reasonable
possibility that a material misstatement of the entity's financial
statements will not be prevented, or detected and corrected, on a
timely basis. A deficiency in internal control exists when the design
or operation of a control does not allow management or employees, in
the normal course of performing their assigned functions, to prevent,
or detect and correct, misstatements on a timely basis.
[16] With regard to the Mint's financial statements for fiscal years
1993 through 2004, the Mint's independent public accountants reported
that they did not audit the gold reserves included in the Mint's
Custodial Schedules. Their opinions on these financial statements, in
so far as they related to such gold reserves, were based solely on the
reports of the Treasury OIG regarding the related Mint Custodial
Schedule.
[End of section]
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