Financial Audit
The Farm Credit System Insurance Corporation's Fiscal Year 2003 Management Representation Letter on Its Financial Statements Gao ID: GAO-05-590R June 23, 2005The Secretary of the Treasury, in coordination with the Director of the Office of Management and Budget (OMB), is required to annually prepare and submit audited financial statements of the U.S. government to the President and the Congress. We are required to audit these consolidated financial statements (CFS) and report on the results of our work. In connection with fulfilling our requirement to audit the fiscal year 2004 CFS, we evaluated the Department of the Treasury's (Treasury) financial reporting procedures and related internal control over the process for compiling the CFS, including the management representation letter provided us by Treasury and OMB. Written representation letters from management, required by U.S. generally accepted government auditing standards, ordinarily confirm oral representations given to the auditor, indicate and document the continuing appropriateness of those representations, and reduce the possibility of a misunderstanding between management and the auditor. The purpose of this report is to communicate our observations on the Farm Credit System Insurance Corporation's (FCSIC) 2003 management representation letter. Our objective is to help ensure that future management representation letters submitted by FCSIC are sufficient to help support Treasury and OMB's preparation of the CFS management representation letter and our ability to rely on the representations in that letter in combination with individual federal agency representation letters. We reviewed five key areas in each management representation letter: (1) signatures, (2) materiality thresholds, (3) representations, (4) summary of unadjusted misstatements, and (5) reliability of representations. In reviewing the management representation letters, we applied the American Institute of Certified Public Accountants' (AICPA) Codification of Auditing Standards, AU Section 333, Management Representations; OMB Bulletin 01-02, Audit Requirements for Federal Financial Statements; and the GAO/President's Council on Integrity and Efficiency (PCIE) Financial Audit Manual (FAM) section 1001, entitled "Management Representations."
FCSIC's 2003 management representation letter did not provide all the information necessary to support Treasury and OMB's preparation of the CFS management representation letter. This in turn impacted our ability to rely on the representations in the CFS management representation letter in combination with individual federal agency representation letters. We identified some needed improvements in two of the five key areas we reviewed. First, FCSIC did not provide the materiality thresholds used to determine, for representation purposes, any matters that were individually or collectively material to its financial statements. Such individual federal agency thresholds are considered by Treasury and OMB in providing a materiality threshold for the CFS representation letter. Second, the letter included 20 of the 25 representations from the FAM that were applicable to FCSIC. For the other 5 representations, 1 was not fully included and 4 were not provided at all. We believe that these matters can be easily addressed. We are making two recommendations to FCSIC's Chief Financial Officer targeted to specific changes needed. Also, we are recommending that FCSIC's Chairman of the Audit Committee, with the contracted independent public accountant, work with the agency to help ensure that future management representation letters meet the key conditions noted as needing improvements in this report.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-590R, Financial Audit: The Farm Credit System Insurance Corporation's Fiscal Year 2003 Management Representation Letter on Its Financial Statements
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June 23, 2005:
Mr. C. Richard Pfitzinger:
Chief Financial Officer:
Farm Credit System Insurance Corporation:
Mr. Douglas Flory:
Chairman of the Audit Committee:
Farm Credit System Insurance Corporation:
Subject: Financial Audit: The Farm Credit System Insurance
Corporation's 2003 Management Representation Letter on Its Financial
Statements:
As you know, the Secretary of the Treasury, in coordination with the
Director of the Office of Management and Budget (OMB), is required to
annually prepare and submit audited financial statements of the U.S.
government to the President and the Congress. We are required to audit
these consolidated financial statements (CFS) and report on the results
of our work.[Footnote 1] In connection with fulfilling our requirement
to audit the fiscal year 2004 CFS, we evaluated the Department of the
Treasury's (Treasury) financial reporting procedures and related
internal control over the process for compiling the CFS, including the
management representation letter provided us by Treasury and OMB.
Written representation letters from management, required by U.S.
generally accepted government auditing standards, ordinarily confirm
oral representations given to the auditor, indicate and document the
continuing appropriateness of those representations, and reduce the
possibility of a misunderstanding between management and the auditor.
In our report, which is included in the fiscal year 2004 Financial
Report of the United States Government,[Footnote 2] we reported a
limitation on the scope of our work due to identified concerns with the
adequacy of certain federal agencies' management representations on
which Treasury and OMB depend to provide their representations to us
regarding the CFS. Specifically, Treasury and OMB stated that their
representation letter to us on the CFS was based primarily on the
individual federal agency representation letters. Consequently, our
audit considered the content of the individual federal agency letters,
and the incompleteness of certain of these letters impaired our ability
to obtain sufficient evidence in support of our audit of the CFS. This
limitation contributed to our disclaimer of opinion on the CFS. We
performed sufficient audit work to provide the disclaimer of opinion
and issued our audit report, dated December 6, 2004, in accordance with
U.S. generally accepted government auditing standards.
As part of our audit of the fiscal year 2004 CFS, we received and
reviewed selected federal agencies' management representation letters
to assess their adequacy in support of our audit of the CFS. As the
federal government gets closer to an opinion on its financial
statements, it becomes more important that the federal agencies'
management representation letters be complete and reliably prepared.
The purpose of this report is to communicate our observations on the
Farm Credit System Insurance Corporation's (FCSIC) 2003 management
representation letter.[Footnote 3] Our objective is to help ensure that
future management representation letters submitted by FCSIC are
sufficient to help support Treasury and OMB's preparation of the CFS
management representation letter and our ability to rely on the
representations in that letter in combination with individual federal
agency representation letters. We reviewed five key areas in each
management representation letter: (1) signatures, (2) materiality
thresholds, (3) representations, (4) summary of unadjusted
misstatements, and (5) reliability of representations. In reviewing the
management representation letters, we applied the American Institute of
Certified Public Accountants' (AICPA) Codification of Auditing
Standards, AU Section 333, Management Representations; OMB Bulletin 01-
02, Audit Requirements for Federal Financial Statements; and the
GAO/President's Council on Integrity and Efficiency (PCIE) Financial
Audit Manual (FAM) section 1001, entitled "Management Representations."
[Footnote 4]
Results in Brief:
FCSIC's 2003 management representation letter did not provide all the
information necessary to support Treasury and OMB's preparation of the
CFS management representation letter. This in turn impacted our ability
to rely on the representations in the CFS management representation
letter in combination with individual federal agency representation
letters.
We identified some needed improvements in two of the five key areas we
reviewed. First, FCSIC did not provide the materiality thresholds used
to determine, for representation purposes, any matters that were
individually or collectively material to its financial statements. Such
individual federal agency thresholds are considered by Treasury and OMB
in providing a materiality threshold for the CFS representation letter.
Second, the letter included 20 of the 25 representations[Footnote 5]
from the FAM that were applicable to FCSIC. For the other 5
representations, 1 was not fully included and 4 were not provided at
all.
We believe that these matters can be easily addressed. We are making
two recommendations to FCSIC's Chief Financial Officer targeted to
specific changes needed. Also, we are recommending that FCSIC's
Chairman of the Audit Committee, with the contracted independent public
accountant, work with the agency to help ensure that future management
representation letters meet the key conditions noted as needing
improvements in this report.
In commenting on a draft of this report, FCSIC's Chief Financial
Officer noted that many of the matters we had discussed in our report
were included in FCSIC's 2004 management representation letter dated
March 15, 2005, and efforts are underway to address the other
conditions. However, FCSIC's Chief Financial Officer stated that we
reviewed FCSIC's 2003 management representation letter, which was
executed in May 2004, against revised standards that were published in
July 2004. During our review, we did apply the FAM dated July 30, 2004.
However, the specific representations discussed in this report as being
incomplete or not provided were called for by the July 2001 version of
the FAM. In addition, FCSIC's Chief Financial Officer advised us orally
that his response was coordinated with FCSIC's Chairman of the Audit
Committee and that the Chairman concurred with our recommendation to
work with the agency to help ensure that future management
representation letters meet the key conditions noted as needing
improvements in this report.
Background:
In conducting agency financial statement audits, U.S. generally
accepted government auditing standards incorporate financial auditing
fieldwork and reporting standards issued by the AICPA. Such auditing
standards (AU Section 333) require auditors to obtain certain
representations from agency management. These representations are part
of the evidential matter to be considered by the auditor in its audit
of the agency's financial statements. The representations obtained will
depend on the circumstances of the engagement and the nature and basis
of presentation of the financial statements. AU Section 333 discusses
specific representations that should be obtained from management,
including a requirement to attach a schedule of unadjusted financial
statement misstatements for entities with uncorrected misstatements.
In addition, OMB Bulletin 01-02 and FAM section 1001 contain guidance
on preparing federal agencies' management representation letters.
According to the FAM, in addition to the representations included in AU
Section 333, the auditor generally should consider the need to obtain
representations on other matters based on the circumstances of the
audited entity. FAM section 1001A lists 35 specific representations
ordinarily included in the management representation letter and also
includes a requirement to attach a schedule of unadjusted financial
statement misstatements for entities with uncorrected misstatements.
(See enc. I for these representations.) Representations listed in FAM
section 1001A should be customized to the situation of the entity being
audited or excluded if inapplicable. We perform our audit of the CFS in
accordance with the FAM and related auditing standards.
Treasury and OMB are to receive management representation letters from
certain federal agencies. This is important because U.S. generally
accepted government auditing standards require that Treasury and OMB
provide us, as principal auditor of the CFS, a management
representation letter, and their letter depends on the information in
such agencies' management representation letters. In their
representation letter to us for the audit of the fiscal year 2004 CFS,
Treasury and OMB stated that their representations are based primarily
on the representations of those agencies covered by the Chief Financial
Officers (CFO) Act and other selected agencies that were made in
connection with the preparation of these entities' respective financial
statements and provided to OMB and Treasury. For this reason, it is
important that all federal agency representation letters be complete
and reliable.
Objectives, Scope, and Methodology:
In connection with our audit of the fiscal year 2004 CFS, we evaluated
Treasury's financial reporting procedures and related internal control,
including the CFS management representation letter. For the fiscal year
2004 CFS, 33 of the 35 "verifying agencies" submitted audited financial
statements along with their management representation letters to
Treasury.[Footnote 6] In our review of these 33 management
representation letters, our overall objective was to assess their
adequacy as it relates to our audit of the CFS. Specifically, we
reviewed each agency management representation letter to determine
whether the following five key conditions were met:
* the management representation letter was signed by appropriate agency
officials;
* the management representation letter included designation as to the
amounts above which matters were considered material (materiality
thresholds);
* the management representation letter included applicable
representations from the FAM;
* the management representation letter included a properly prepared
summary of unadjusted misstatements for agencies with uncorrected
misstatements; and:
* the representations in the management representation letter were
reliable based on a review of findings in the auditor's report.
This report is based on the audit work we performed for the audit of
the fiscal year 2004 CFS, which was performed in accordance with U.S.
generally accepted government auditing standards.
We requested comments on a draft of this report from FCSIC's Chief
Financial Officer and Chairman of the Audit Committee or their
designees. Written comments from FCSIC's Chief Financial Officer are
reprinted in enclosure II. The Chief Financial Officer advised us
orally that his response was coordinated with FCSIC's Chairman of the
Audit Committee.
Identified Issues with FCSIC's 2003 Management Representation Letter:
With respect to FCSIC's 2003 management representation letter, we
identified the following two areas that need some improvement: (1)
providing the materiality thresholds used and (2) providing or fully
including applicable representations from the FAM. Details regarding
these issues are as follows.
Providing the Materiality Thresholds Used:
Management representations may be limited to matters that are
considered individually or collectively material to the entity's
financial statements, provided that management and the auditor have
reached an understanding on the materiality thresholds to be used.
Likewise, in preparing the overall management representation letter for
the CFS, which is provided to us, Treasury and OMB limit the letter's
representations to matters that are considered to be material. While an
understanding between management and the auditor of materiality
thresholds used is not explicitly required by auditing standards to be
included in the management representation letter, Treasury and OMB use
agency thresholds in providing a materiality threshold for the
governmentwide management representation letter.
For fiscal year 2004, because the materiality thresholds used were not
included in FCSIC's and a number of other federal agencies' management
representation letters, or otherwise provided to Treasury and OMB,
Treasury and OMB's ability to represent that all matters material to
the CFS were properly considered and included in the overall management
representation letter for the CFS was impaired.
Providing or Fully Including Applicable Representations from the FAM:
Written representations from management ordinarily confirm oral
representations made to the auditor during the audit, document the
continuing appropriateness of those representations, and reduce the
possibility of a misunderstanding. To meet auditing standards and OMB
requirements, federal agencies' management and auditors need to ensure
that management representation letters are complete and accurate.
We found that FCSIC's 2003 management representation letter included 20
of the 25 representations from the FAM that were applicable to FCSIC.
Of the 5 other representations, 1 was not fully included and 4 were not
provided at all. For the incomplete representation, the FCSIC
management representation letter included the following representation
intended to cover the intraentity transactions and balances
representation called for by FAM 10. (See enc. I for this
representation.)
"The Corporation has appropriately reconciled its books and records
(e.g., general ledger accounts) underlying the financial statements to
their related supporting information (e.g., sub ledger or third-party
data). All related reconciling items considered to be material were
identified and included on the reconciliations and were appropriately
adjusted in the financial statements. There were no material
unreconciled differences or material general ledger suspense account
items that should have been adjusted or reclassified to another account
balance. There were no material general ledger suspense account items
written off to a balance sheet account, which should have been written
off to an income statement account and vice versa. All intracompany
accounts have been eliminated or appropriately measured and considered
for disclosure in the financial statements."
While this representation addresses intraentity transactions and
balances, it should also address intragovernmental transactions and
balances as called for by FAM 10.
In addition, the four representations not provided were as follows.
* FAM #14: We are responsible for establishing and maintaining internal
control.
* FAM #25: We are responsible for the agency's compliance with
applicable laws and regulations.
* FAM #26: We have identified and disclosed to you all laws and
regulations that have a direct and material effect on the determination
of financial statement amounts.
* FAM #27: We have disclosed to you all known instances of
noncompliance with laws and regulations.
When agencies do not provide all representations or include incomplete
representations in their management representation letters, it impairs
our ability to audit the CFS and Treasury and OMB's ability to make
these types of representations in the CFS management representation
letter.
Conclusions:
In two of the five key areas we reviewed, FCSIC's 2003 management
representation letter did not provide all the information necessary to
support Treasury and OMB's preparation of the CFS management
representation letter and our ability to rely on the representations in
that letter in combination with individual federal agency
representation letters, including that of FCSIC. The additional
information needed from FCSIC is straightforward and should be easy to
address.
Recommendations for Executive Action:
We recommend to FCSIC's Chief Financial Officer that in the future the
management representation letter:
* include materiality thresholds or such thresholds be provided
separately to Treasury and OMB and:
* fully include all representations from the FAM that are applicable to
FCSIC.
We recommend that the FCSIC's Chairman of the Audit Committee, with the
contracted independent public accountant, work with the agency to help
ensure that future management representation letters meet the key
conditions noted as needing improvements in this report.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, which are reprinted in
enclosure II, FCSIC's Chief Financial Officer noted that many of the
matters we had discussed in our report were included in FCSIC's 2004
management representation letter dated March 15, 2005, and that efforts
are underway to address the other conditions noted in our report.
Specifically, he stated that 3 of the 5 representations listed in our
report were included in FCSIC's 2004 management representation letter
and FCSIC will include language for the other 2 representations in
subsequent management representation letters. The Chief Financial
Officer also stated that his office is working with FCSIC's external
auditors on an appropriate methodology to provide the materiality
thresholds. However, FCSIC's Chief Financial Officer stated that we
reviewed FCSIC's 2003 management representation letter, which was
executed in May 2004, against revised standards that were published in
July 2004. During our review, we did apply the FAM dated July 30, 2004.
However, the specific representations discussed in this report as being
incomplete or not provided were called for by the July 2001 version of
the FAM. In addition, FCSIC's Chief Financial Officer advised us orally
that his response was coordinated with FCSIC's Chairman of the Audit
Committee and that the Chairman concurred with our recommendation to
work with the agency to help ensure that future management
representation letters meet the key conditions noted as needing
improvements in this report.
Within 60 days of the date of this report, we would appreciate
receiving a written statement on actions taken to address these
recommendations.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of the Senate Committee on Homeland Security and
Governmental Affairs; the Subcommittee on Federal Financial Management,
Government Information, and International Security, Senate Committee on
Homeland Security and Governmental Affairs; the House Committee on
Government Reform; and the Subcommittee on Government Management,
Finance, and Accountability, House Committee on Government Reform. In
addition, we are sending copies to the Fiscal Assistant Secretary of
the Treasury and the Controller of OMB. Copies will be made available
to others upon request. This report is also available at no charge on
GAO's Web site at [Hyperlink, http://www.gao.gov].
We appreciate the courtesy and cooperation extended to us by your staff
throughout our work. We look forward to continuing to work with your
offices to help improve financial management in the federal government.
If you have any questions about the contents of this report, please
contact me at (202) 512-3406.
Signed by:
Gary T. Engel:
Director:
Financial Management and Assurance:
Enclosures - 2:
[End of section]
Enclosure I: Representations in FAM 1001A:
Guidance contained in FAM 1001 and FAM 1001A deals with the management
representations that the auditor should obtain from current management
as part of the audit. This guidance also acknowledges that judgment
needs to be exercised to obtain representations that depend on the
circumstances of the engagement and the nature and basis of
presentation of the financial statements. Representations given in FAM
section 1001A should be customized to the situation of the entity being
audited, and additional representations may need to be obtained.
FAM 1001A lists 27 representations that are ordinarily included, if
applicable, in the management representation letter that an agency
provides to the auditor. For representations 3, 11, 16, and 18, the
agency should address three separate components. As such, each agency
is ordinarily expected to make a total of 35 representations.
Representations 18, 19, 20, and 21 are not applicable unless the agency
received an opinion on its internal control. In addition,
representations 22, 23, and 24 address the three requirements of the
Federal Financial Management Improvement Act of 1996 and are only
applicable to the 24 CFO Act agencies. The 35 representations in FAM
1001A are as follows.
1. We are responsible for the fair presentation of the financial
statements and stewardship information in conformity with U.S.
generally accepted accounting principles.
2. The financial statements are fairly presented in conformity with
U.S. generally accepted accounting principles.
3. We have made available to you all:
* financial records and related data;
* where applicable, minutes of meetings of the Board of Directors [or
other similar bodies, such as congressional oversight committees] or
summaries of actions of recent meetings for which minutes have not been
prepared; and:
* communications from the Office of Management and Budget (OMB)
concerning noncompliance with or deficiencies in financial reporting
practices.
4. There are no material transactions that have not been properly
recorded in the accounting records underlying the financial statements
or disclosed in the notes to the financial statements.
5. We believe that the effects of the uncorrected financial statement
misstatements summarized in the accompanying schedule are immaterial,
both individually and in the aggregate, to the financial statements
taken as a whole. [If management believes that certain of the
identified items are not misstatements, management's belief may be
acknowledged by adding to the representation, for example, "We believe
that items XX and XX do not constitute misstatements because
[description of reason]."]
6. The [entity] has satisfactory title to all owned assets, including
stewardship property, plant, and equipment; such assets have no liens
or encumbrances; and no assets have been pledged.
7. We have no plans or intentions that may materially affect the
carrying value or classification of assets and liabilities.
8. Guarantees under which the [entity] is contingently liable have been
properly reported or disclosed.
9. Related party transactions and related accounts receivable or
payable, including assessments, loans, and guarantees, have been
properly recorded and disclosed.
10. All intraentity transactions and balances have been appropriately
identified and eliminated for financial reporting purposes, unless
otherwise noted. All intragovernmental transactions and balances have
been appropriately recorded, reported, and disclosed. We have
reconciled intragovernmental transactions and balances with the
appropriate trading partners for the four fiduciary transactions
identified in Treasury's Intra-governmental Fiduciary Transactions
Accounting Guide, and other intragovernmental asset, liability, and
revenue amounts as required by the applicable OMB Bulletin.
11. There are no:
* possible violations of laws or regulations whose effects should be
considered for disclosure in the financial statements or as a basis for
recording a loss contingency,
* material liabilities or gain or loss contingencies that are required
to be accrued or disclosed that have not been accrued or disclosed, or:
* unasserted claims or assessments that are probable of assertion and
must be disclosed that have not been disclosed.
12. We have complied with all aspects of contractual agreements that
would have a material effect on the financial statements in the event
of noncompliance.
13. No material events or transactions have occurred subsequent to
September 30, 20X2 [or date of latest audited financial statements],
that have not been properly recorded in the financial statements and
stewardship information or disclosed in the notes.
14. We are responsible for establishing and maintaining internal
control.
15. We acknowledge our responsibility for the design and implementation
of programs and controls to prevent and detect fraud (intentional
misstatements or omissions of amounts or disclosures in financial
statements and misappropriation of assets that could have a material
effect on the financial statements).
16. We have no knowledge of any fraud or suspected fraud affecting the
[entity] involving:
* management,
* employees who have significant roles in internal control, or:
* others where the fraud could have a material effect on the financial
statements.
[If there is knowledge of any such instances, they should be described.]
17. We have no knowledge of any allegations of fraud or suspected fraud
affecting the [entity] received in communications from employees,
former employees, or others. [If there is knowledge of any such
allegations, they should be described.]
18. Pursuant to 31 U.S.C. 3512(c), (d) (commonly known as the Federal
Managers' Financial Integrity Act), we have assessed the effectiveness
of the [entity's] internal control in achieving the following
objectives:
* reliability of financial reporting--transactions are properly
recorded, processed, and summarized to permit the preparation of
financial statements and stewardship information in accordance with
U.S. generally accepted accounting principles, and assets are
safeguarded against loss from unauthorized acquisition, use or
disposition;
* compliance with applicable laws and regulations--transactions are
executed in accordance with (i) laws governing the use of budget
authority and with other laws and regulations that could have a direct
and material effect on the financial statements and (ii) any other
laws, regulations, and governmentwide policies identified by OMB in its
audit guidance; and:
* reliability of performance reporting--transactions and other data
that support reported performance measures are properly recorded,
processed, and summarized to permit the preparation of performance
information in accordance with criteria stated by management.
[If the entity bases its internal control assessment on suitable
criteria other than 31 U.S.C. 3512(c), (d), this item should cite the
criteria used (for example, Internal Control--Integrated Framework
issued by the Committee of Sponsoring Organizations (COSO) of the
Treadway Commission).]
19. Those controls in place on September 30, 20X2 [or date of latest
audited financial statements], and during the years ended 20X2 and
20X1, provided reasonable assurance that the foregoing objectives are
met. [If there are material weaknesses, the foregoing representation
should be modified to read:
* Those controls in place on September 30, 20X2, and during the years
ended 20X2 and 20X1, provided reasonable assurance that the foregoing
objectives are met except for the effects of the material weaknesses
discussed below or in the attachment.
* or: Internal controls are not effective.
* or: Internal controls do not meet the foregoing objectives.]
20. We have disclosed to you all significant deficiencies in the design
or operation of internal control that could adversely affect the
entity's ability to meet the internal control objectives and identified
those we believe to be material weaknesses.
21. There have been no changes to internal control subsequent to
September 30, 20X2 [or date of latest audited financial statements], or
other factors that might significantly affect it. [If there were
changes, describe them, including any corrective actions taken with
regard to any significant deficiencies or material weaknesses.]
22. We are responsible for implementing and maintaining financial
management systems that substantially comply with federal financial
management systems requirements, federal accounting standards (U.S.
generally accepted accounting principles), and the U.S. Government
Standard General Ledger at the transaction level.
23. We have assessed the financial management systems to determine
whether they substantially comply with these federal financial
management systems requirements. Our assessment was based on guidance
issued by OMB.
24. The financial management systems substantially complied with
federal financial management systems requirements, federal accounting
standards, and the U.S. Government Standard General Ledger at the
transaction level as of [date of the latest financial statements].
[If the financial management systems substantially comply with only one
or two of the above elements, this representation should be modified as
follows:
* As of [date of financial statements], the [entity's] financial
management systems substantially comply with [specify which of the
three elements for which there is substantial compliance (e.g., federal
accounting standards and the SGL at the transaction level)], but did
not substantially comply with [specify which of the elements for which
there was a lack of substantial compliance (e.g., federal financial
management systems requirements)], as described below (or in an
attachment).]
[If the financial management systems do not substantially comply with
any of the three elements, the following paragraph should be used
instead:
* As of [date of financial statements], the [entity's] financial
management systems do not substantially comply with the federal
financial management systems requirements.]
[If there is a lack of substantial compliance with one or more of the
three requirements, identify herein or in an attachment all the facts
pertaining to the noncompliance, including the nature and extent of the
noncompliance and the primary reason or cause of the noncompliance.]
25. We are responsible for the [entity's] compliance with applicable
laws and regulations.
26. We have identified and disclosed to you all laws and regulations
that have a direct and material effect on the determination of
financial statement amounts.
27. We have disclosed to you all known instances of noncompliance with
laws and regulations.
[End of section]
Enclosure II: Comments From the Farm Credit System Insurance
Corporation:
Farm Credit System Insurance Corporation:
June 13, 2005:
Mr. Gary T. Engel:
Director, Financial Management and Assurance:
United States Government Accountability Office:
Dear Mr. Engel,
This letter is in response to your correspondence dated May 18, 2005,
regarding the Farm Credit System Insurance Corporation's (FCSIC) 2003
Management Representation Letter.
We understand the objective is to obtain management representation
letters that are sufficient to support the U.S. Treasury and OMB's
preparation of the consolidated financial statement management
representation letter. As noted in footnote 3 of your draft letter,
FCSIC's financial statements are based on a calendar year reporting
period and are prepared in accordance with Generally Accepted
Accounting Principles in the United States. GAO reviewed the
Corporation's 2003 Management Representation Letter which was executed
in May 2004 against revised standards that were published July 30, 2004
(see GAO draft letter, footnote 4).
A review of FCSIC's 2004 Management Representation Letter, issued May
2005, shows that we provided three of the four representations that
your correspondence states were omitted in the 2003 Management
Representation Letter. The three representations outlined in the
Financial Audit Manual (FAM) that you listed and we provided in the
2004 Management Representation Letter are:
* FAM #25 We are responsible for the agency's compliance with
applicable laws and regulations. (Our response was provided on page 2,
number 10 of the 2004 Management Representation Letter, copy attached.)
* FAM #26 We have identified and disclosed to you all laws and
regulations that have a direct and material effect on the determination
of financial amounts (page 2, number 11).
* FAM #27 We have disclosed to you all known instances of noncompliance
with laws and regulations (page 2, number 12).
To address the fourth representation you listed, FAM #14 (We are
responsible for establishing and maintaining internal control), we will
amend our current representation on internal controls to include this
language. Our current language from 2004 read as follows: "There are no
significant deficiencies, including material weaknesses, in the design
or operation of internal control over financial reporting that are
reasonably likely to adversely affect the Corporation's ability to
record, process, summarize and report financial data" (page 2, number
5). Annually, we conduct the Financial Managers' Financial Integrity
Act audit and along with our external auditors, we have found our
internal controls to be sound.
We will also amend the representation for (FAM #10) to include
intragovernmental transactions and balances in subsequent management
representation letters.
Finally, with regard to disclosing specific materiality testing
thresholds, we agree with your statement that the inclusion of
materiality thresholds in the management representation letter is not
required by auditing standards. However, we understand Treasury and OMB
use of agency thresholds in providing materiality thresholds for the
Governmentwide Management Representation Letter. We are currently
working with our external auditors, PricewaterhouseCoopers, on an
appropriate methodology to provide this information.
Sincerely,
Signed by:
C. Richard Pfitzinger:
Chief Financial Officer:
Enclosure:
2004 Management Representation Letter:
[End of section]
(198369):
FOOTNOTES
[1] The Government Management Reform Act of 1994 has required such
reporting, covering the executive branch of government, beginning with
financial statements prepared for fiscal year 1997. 31 U.S.C. § 331
(e). The federal government has elected to include certain financial
information on the legislative and judicial branches in the CFS as
well.
[2] The fiscal year 2004 Financial Report of the United States
Government was completed by the Department of the Treasury on December
15, 2004, and is available through both GAO's Web site at www.gao.gov
and Treasury's Web site at www.fms.treas.gov/fr/index.html.
[3] FCSIC's reporting period ends on December 31. Since FCSIC's 2004
management representation letter was not yet available, we used FCSIC's
2003 management representation letter for purposes of this review.
[4] GAO, GAO/PCIE: Financial Audit Manual: Update, GAO-04-1015G
(Washington, D.C.: July 30, 2004), an update to Financial Audit Manual:
Volumes 1 and 2, GAO-01-765G (Washington, D.C.: Aug. 1, 2001).
[5] The FAM lists 27 representations that are ordinarily included, if
applicable, in the management representation letter that an agency
provides to the auditor. For 4 of the representations, the agency is
required to address three separate components. As such, each agency is
ordinarily expected to make a total of 35 representations. However,
because FCSIC's reporting period ends December 31, for purposes of this
review, we used FCSIC's 2003 management representation letter and, as
such, the representation related to any uncorrected misstatements as of
September 30, 2004, was not applicable. In addition, 6 of the 35
representations are not applicable unless the agency received an
opinion on its internal control. Further, 3 representations are only
applicable to the 23 CFO Act agencies. Since FCSIC's reporting period
ends December 31, FCSIC did not receive an opinion on its internal
control for fiscal year 2004, and FCSIC is not a CFO Act agency, only
25 of the 35 representations were applicable to FCSIC's 2003 management
representation letter.
[6] See Treasury Financial Manual, vol. I, part 2, ch. 4700, for a list
of the 35 agencies. These agencies, for fiscal year 2004, consisted of
23 CFO Act agencies and 12 material other agencies. The 33 agencies we
reviewed did not include the U.S. Securities and Exchange Commission
and the Smithsonian Institution because these audits were not complete
before the fiscal year 2004 Financial Report of the United States
Government was issued. The Department of Homeland Security (DHS)
Financial Accountability Act, Pub. L. No. 108-330, 118 Stat. 1275 (Oct.
16, 2004), added DHS to the list of CFO Act agencies, increasing the
number of CFO Act agencies again to 24 for fiscal year 2005.
