The FDIC is a leader in developing and implementing sound public policies,
identifying and addressing new and existing risks in the nation’s financial system,
and effectively and efficiently carrying out its insurance, supervisory, and
receivership management responsibilities.
.
Values
The OIG also embraces the Corporation’s core values that follow:
Integrity. FDIC employees adhere to the highest ethical standards in the performance of their
duties and responsibilities.
Competence. The FDIC maintains a highly skilled, dedicated, and diverse workforce.
Teamwork. FDIC employees work cooperatively with one another and with employees in other
regulatory agencies to accomplish the Corporation’s mission.
Effectiveness. The FDIC responds quickly and successfully to identified risks in insured
financial institutions and in the broader financial system.
Financial Stewardship. The FDIC acts as a responsible fiduciary, consistently operating in an
efficient and cost-effective manner on behalf of insured financial institutions and other
stakeholders.
Fairness. The FDIC treats all employees, insured financial institutions, and other stakeholders
with impartiality and mutual respect.
Strategic Outlook
This section summarizes the OIG’s strategic outlook and environment as we strive to achieve our
mission through accomplishment of our strategic goals and objectives.
Corporate Environment and Management Challenges at the FDIC
Corporate Environment
The strategic outlook for the OIG, established within the corporate environment, must
necessarily give primary consideration to the challenges that the Corporation will face now and
in the future in meeting its mission. Accordingly, the OIG must continually evaluate major
corporate challenges and issues in order to identify corporate vulnerabilities (to fraud, abuse, and
inefficient, uneconomical and ineffective activities) that we must address to meet our mission
under the Inspector General Act.
FDIC Chairman Donald Powell has articulated a strategic vision for the FDIC. He believes the
Corporation should provide timelier and better banking-related information than anyone else;
recognize and respond to emerging risks before they threaten safety and soundness or harm
consumers; and become the authority and resource that the Congress, media, and others turn to
for guidance.
Corporate Performance Objectives have been developed for 2005 to continue the FDIC’s efforts
to accomplish the Chairman’s vision. These performance objectives are focused on strategic
change initiatives that have corporate-wide significance and are grouped under the areas of
Sound Policy, Stability, and Stewardship. Performance Objectives under Sound Policy include
initiatives relating to policy leadership, research contributions, deposit insurance reform
legislation, and reducing regulatory burden. Objectives under Stability include initiatives
relating to insuring and supervising large banks, effectiveness of risk analysis and fund
management processes, banking system protection, improving bank supervision, and banking
data availability to the public. Stewardship objectives are included to reduce corporate operating
costs, promote a high-performing workforce, improve the Corporation’s information technology
program, and effectively manage capital investment projects.
The OIG fully supports the Chairman’s vision and the associated objectives and initiatives by the
Corporation and will do all it can, in partnership with the Corporation, other financial regulatory
agencies, and the Inspector General community, to help make it a reality.
Management and Performance Challenges Facing the FDIC
In the interest of improving federal performance government-wide, the Senate Governmental
Affairs Committee has asked Offices of Inspector General to annually identify the most
significant management challenges facing their agencies. At the FDIC, our office has identified
and reported these challenges to the Chairman, the Congress, and others through our Semiannual
Reports to the Congress. In addition, the Reports Consolidation Act of 2000 (RCA) provides
that an agency producing a consolidated performance and accountability report will include a
statement prepared by the agency’s Inspector General that summarizes the most serious
management and performance challenges facing the agency. Beginning in 2002, the FDIC decided to prepare a consolidated performance and accountability report consistent with the
RCA. This report consolidates the FDIC’s Chief Financial Officers Act Report, the GPRA
Program Performance Report, and the traditional Annual Report. In the spirit of the RCA, the
Inspector General provides for inclusion in the consolidated annual report a statement that
identifies and assesses the most serious management and performance challenges facing the
Corporation. For the FDIC’s 2004 Annual Report to be published in February 2005, the OIG
identified management and performance challenges in the following seven areas:
- Corporate Governance in Insured Depository Institutions
- Management and Analysis of Risks to the Insurance Funds
- Security Management
- Money Laundering and Terrorist Financing
- Protection of Consumers’ Interests
- Corporate Governance in the FDIC
- Resolution and Receivership Activities
The OIG will continue to evaluate and annually update the challenges and will pursue audits,
evaluations, investigations, and other reviews that address these challenges and related corporate
risks. A detailed description of the management and performance challenges can be viewed on
the OIG’s Internet Web Site by visiting http://www.fdicoig.gov/gpra/MPCs_12-16-2004.pdf.
OIG Strategic Challenges and Strategies
The OIG is faced with the challenge of designing audit, evaluation and investigative strategies
which provide the highest value, or greatest return, in identifying and minimizing the
vulnerabilities and risks the Corporation faces as it addresses the formidable challenges
delineated above. As the Corporation identifies its priorities and develops its strategies to
operate into the future, the OIG recognizes it must stay abreast of changes and reevaluate its
priorities and strategies in light of the Corporation’s needs.
Audit and Evaluation Strategies
The Office of Audits develops and issues annual Assignment Plans which present audit and
evaluation assignments designed to help the FDIC successfully address risks, meet its many
challenges, and accomplish its strategic goals. The plan provides a key mechanism to assist the
OIG in achieving its first strategic goal (value and impact): OIG products will add value by
achieving significant impact related to addressing issues of importance to the Chairman, the
Congress, and the public.
The Office of Audits Assignment Plan is based on the OIG’s assessment of risks that the FDIC
faces in meeting its strategic goals and objectives, consistent with the Chairman’s priorities.
This risk assessment process is linked to the OIG’s identification of management and
performance challenges, as discussed above. This planning process is coordinated with the
FDIC Audit Committee and senior FDIC management. Reports and products issued under the
assignment plan are intended to produce constructive recommendations for improving programs
and activities, and achieve economies and efficiencies in operations. As such, we believe the
assignments will enhance FDIC corporate governance and contribute to the Corporation’s overall
risk management activities. The FY 2005 Office of Audits Assignment Plan can be viewed on
the OIG’s Internet Web Site by visiting http://www.fdicig.gov/FY05AssignmentPlan/FY05AP.pdf.
Audit and evaluation work addresses the Corporation's three principal operational areas as
discussed in the FDIC Strategic Plan – Insurance, Supervision, and Receivership Management.
Our work also addresses a fourth area of corporate attention discussed in the FDIC Strategic
Plan – Resource Management. This includes the FDIC’s human, financial, and technological
resources essential to the successful accomplishment of the Corporation’s mission and its annual
performance goals. The organization structure of the Office of Audits focuses on these strategic
areas.
The Office of Audits manages its audit and evaluation activity through the following six
operating directorates:
- Supervision and Insurance
- Resolution, Receivership, and Legal Services
- Information Assurance
- Systems Management
- Resources Management
- Corporate Evaluations (performs reviews that crosscut corporate operational areas)
The Office of Audits also maintains flexibility in its assignment planning to meet the changing
needs of the Corporation. In keeping with the OIG’s commitment to perform assignments that
are meaningful to the Corporation and that address corporate risks, the Office of Audits will be
mindful of the “next best assignment to perform” to ensure that all assignments meet identified
and emerging risks. To this end, during the fiscal year, higher priority assignments may be
substituted for those provided in the assignment plan, as appropriate.
Investigative Strategies
OIG investigative strategies and initiatives will add value to the Corporation’s programs and
operations by identifying and investigating instances of fraud, waste, and abuse and other
conduct leading to criminal, civil, and administrative penalties and recoveries. Several key
investigative strategies and initiatives are discussed below.
Solvent/Insolvent Banks
– The OIG continues to work closely with U.S. Attorneys’ Offices,
the FBI, and FDIC’s Division of Supervision and Consumer Protection (DSC) in addressing
fraud at open and failed institutions. As federal law enforcement resources have had to be
redirected to terrorism investigations, U.S. Attorneys’ Offices and the FBI are increasingly
seeking OIG assistance in pursuing investigations of fraud at open and failed institutions. In
addition to criminal prosecutions stemming from its investigations at open and failed
institutions, the OIG has been working with the FDIC Legal Division and DSC to incorporate
appropriate enforcement actions in the plea bargaining process, to prohibit offenders from
future participation in banking.
- Communication with DSC – The OIG communicates on an ongoing basis with DSC on
matters relating to investigations of fraud at both open and closed institutions. Our
relationship with DSC with respect to these cases has become increasingly collaborative as
we work together to aggressively combat fraud and obstruction that harm FDIC regulated
and/or insured institutions. To this end, we meet routinely with DSC officials. In addition to
quarterly meetings with DSC’s Special Activities Section in Washington, OIG
representatives make regular visits to DSC regional and area offices to hold meetings with
DSC managers. On average we visit two offices a quarter, with a goal of visiting all eight
offices each year. During these meetings, we review our ongoing cases involving open and
closed institutions and discuss issues of mutual concern. In addition to these management
meetings, OIG agents have been making presentations to DSC staff at various field offices, to
provide an overview of our Office of Investigations operations and address our role in
investigating financial institution fraud. The OIG continues to work with DSC and other
FDIC program offices in developing and presenting training on “lessons learned” from our
cases that may provide insight into bank failures and red flags of fraud at financial
institutions.
In addition, the OIG issues quarterly reports to DSC officials outlining the status of
investigations involving open and failed institutions. At the conclusion of these cases, we
also issue memorandum reports to DSC outlining the results of the investigation. As actions
of significance occur in our cases, we provide DSC with relevant highlight reports, copies of
indictments, and relevant press releases and news articles. Working collaboratively, the OIG
and DSC have issued a revised agreement relating to our investigations at open institutions,
under which DSC now notifies the OIG of the filing of certain of Suspicious Activity
Reports.
Cooperative Efforts with DRR/Legal
– The OIG continues to coordinate closely with the
FDIC’s Division of Resolutions and Receiverships (DRR) and the Legal Division to address
fraudulent concealment of assets by those who have been ordered to pay FDIC restitution.
Under protocol established between our offices, the OIG will undertake a criminal
investigation when DRR/Legal finds evidence that an individual has concealed or
fraudulently transferred assets to avoid payment of restitution to the FDIC. The OIG and
DRR worked together to issue new guidelines outlining our respective roles at bank closings.
The OIG continues to attend all bank closings where fraud is suspected and to coordinate
with DRR before, during and after the closing. The new guidelines are designed to preserve
evidence for criminal prosecution purposes while enabling DRR to access and protect records
necessary for resolution of the institution. The OIG continues to hold quarterly meetings
with DRR/Legal Headquarters officials and meets periodically with DRR managers in
Dallas. The OIG also issues quarterly reports to DRR and Legal officials outlining our
investigations related to failed institutions, asset concealment, and fraud in the sale of assets.
As significant actions occur in these cases, we provide DRR with relevant highlight reports,
copies of indictments, and related press releases and news articles. We also forward all
judgment orders stemming from our cases to DRR for their use in collecting court-ordered
restitution. The OIG has also been working with DRR and other FDIC officials in
identifying red flags and patterns of fraud found in failed bank institutions. Our agents also
make periodic presentations to DRR and Legal staff outlining “lessons learned” from our
bank failure investigations.
- Electronic Crimes Unit – As computers continue to become a major part of the business
operational environment, the risk of electronic-related fraud has increased. The OIG is
committed to meeting the needs of the FDIC and the banking community to combat
electronic fraud. As a result, the OIG established an Electronic Crimes Unit (ECU) and
computer forensic laboratory, housed in Washington, DC, to investigate unauthorized
computer intrusions and computer-related fraud impacting FDIC operations, and to provide
computer forensic support to OIG investigations. The ECU coordinates with DIRM and
affected FDIC program offices in investigating computer-related crimes. In providing
computer forensic support to OIG investigations, the ECU prepares search warrants for
electronic media, provides on-site support for serving such warrants, conducts laboratory
analysis of the evidentiary content of electronic media seized during criminal investigations,
and provides technical advice regarding computer media used to perpetrate traditional
crimes. The ECU attends all bank closings where fraud is suspected, and images computer
data for evidentiary purposes in resultant criminal prosecutions. The ECU shares copies of
the imaged files with the FDIC for its use in resolving the institution and pursuing bond
claims. The ECU has also been assisting DRR/Legal as they research the feasibility of
creating imaging capability of their own. The ECU worked with DRR in developing
guidelines to be followed at bank closings for the purpose of preserving evidence and attends
meetings with closing team members in advance of scheduled bank closings, to review the
bank’s computer configuration and reach agreement on how to proceed with securing data at
the closing. OIG ECU agents receive intensive training on how to search, seize, and analyze
computer systems and evidence encountered during the course of an investigation and during
execution of search warrants. The ECU has made training presentations to FDIC staff at
various conferences and meetings to make them aware of the ECU capabilities and to outline
procedures that should be followed to preserve computer evidence.
Resource Management and Mission Support Strategies
Achieving audit, evaluation, and investigative strategies requires critical mission support
functions and effective management of human capital, technology, and processes for quality
assurance and risk management. Mission support offices and resource management strategies
for these areas are discussed beginning on page 18.
Strategic Goals, Objectives, and Annual Performance Goals
The FY 2005 performance plan identifies 39 specific performance goals that the OIG will
accomplish during the year to help us achieve our strategic goals and objectives. These
performance goals as well as the strategic goals and objectives are presented graphically on the
next several pages. Page 12 presents the OIG’s mission and strategic goals in relation to the
FDIC’s mission and strategic goals. As portrayed on this page, the OIG’s strategic goals link to
and directly support the FDIC’s strategic goals. Presented separately on pages 13-17 are the
OIG’s four strategic goals, which are briefly described below, and the related strategic objectives
and annual performance goals.
- Value and Impact – Strategic Goal 1 focuses on products adding value to the
Corporation and achieving significant impact by addressing issues of importance to
the Chairman, the Congress, and the public. The FY 2005 plan contains 11 annual
performance goals related to value and impact.
- Communication and Outreach – Strategic Goal 2 focuses on fostering effective
communications and relations with the agency, Congress, OIG employees, and our
other stakeholders. The FY 2005 plan contains 7 annual performance goals related to
communication and outreach.
Human Capital – Strategic Goal 3 focuses on aligning and integrating our human
capital policies and procedures to support the OIG mission. The FY 2005 plan
contains 3 annual performance goals related to human capital.
Productivity – Strategic Goal 4 focuses on effectively managing our resources to
improve the quality and efficiency of our products and processes. The FY 2005 plan
contains 18 annual performance goals related to productivity and efficiency.
In recognizing the dynamic nature of planning and performance measurement, we are committed
to the continued development of performance indicators and goals that better measure the impact
and results of our work.

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Resource Management
Mission Support Offices
The OIG must maintain vital mission support functions in addition to the audit, evaluation, and
investigative functions discussed in the Strategic Outlook section of this plan. Brief descriptions
of the offices providing this critical mission support are presented below.
Office of Counsel
Independent legal services for the OIG, provided by the Counsel to the Inspector General, are a
key activity. Counsel’s services encompass every facet of OIG operations, including performing
research and providing legal advice, counseling, or opinions on audit-, investigative-, and
management-related topics; conducting or assisting with litigation affecting the OIG, including
personnel issues; preparing subpoenas, and seeking to enforce them when necessary; reviewing
proposed legislation and regulations affecting the FDIC; processing requests under the Freedom
of Information Act or the Privacy Act and any related appeals; and representing and negotiating
on behalf of OIG clients vis-à-vis other officials within the FDIC, other government agencies,
Congress, or other persons outside the FDIC.
Office of Management and Congressional Relations
Effectively managing the OIG’s business activities is essential to OIG operations. The OIG’s
Office of Management and Congressional Relations is responsible for this activity and handles
an assortment of responsibilities associated with budgets and financial management, contract
administration, human resources, employee development and training, coordination of officewide
policy development and communication, information systems development, and the OIG’s
information technology strategic planning. This unit also manages the OIG’s relations with
Congress; responds to congressional inquiries; and coordinates the OIG’s review of proposed
legislation and draft corporation policies and procedures.
Office of Quality Assurance and Oversight
Ensuring the quality of OIG work is a high priority. The Office of Quality Assurance and
Oversight is responsible for maintaining quality assurance and organizational self-assessment
programs for OIG activities; performing external quality assurance reviews of other OIGs;
internal coordination and external oversight of risk management and internal control activities
under the Chief Financial Officers Act and the Federal Managers’ Financial Integrity Act; and
internal and external coordination of strategic and annual performance planning and reporting
activities under the Government Performance and Results Act.
Strategic Focus Areas
The effective management of OIG’s human capital, information technology, and quality
assurance and risk management process improvement programs is essential for efficiently
achieving the OIG’s mission, strategic goals and objectives, and annual performance goals.
Effective management is accomplished by providing strategic focus in these areas as follows:
Human Capital
Corporate Environment
A rapidly consolidating financial services industry is prompting the FDIC to recalibrate its
priorities so the Corporation can maintain its footing as a premiere regulator. Over the last 20
years, there has been a 50 percent reduction in insured financial institutions, from more that
18,000 in 1985 to about 9,000 today, according to Deputy to the Chairman and Chief Financial
Officer, Steve App. During that same time there has been a 40 percent reduction in FDICsupervised
institutions from 8,700 to about 5,200. In the meantime, the largest 100 banks have
continued to grow in asset size, and they now comprise about 70 percent of all industry assets.
The FDIC must be ready to operate effectively in this environment.
In August 2004, Deputy to the Chairman and Chief Operating Officer John Bovenzi began a
series of communications to share an evolving strategic vision relating to FDIC’s “Workforce
Planning for the Future.” In working to develop a collective vision for the Corporation’s future
business model and workforce profile, he described a number of preliminary conclusions
regarding the financial institution and regulatory environment, including changes and a
continuation of ongoing trends within the industry. Two conclusions directly related to the
Corporation’s workforce were that (1) existing skill sets would continue and would need to be
augmented by new skill sets not now available in the workforce, and (2) the FDIC of the future
will be a smaller more flexible agency. FDIC divisions and offices will work to ensure their
collective workforce has the organization focus and composition to be properly aligned with
future corporate needs.
As a means of developing a workforce with a corporate perspective that is capable of working
collaboratively to accomplish mission critical functions and responding rapidly to changes in
workload, a new Corporate Employee Program was established to help create a culture that both
encourages and rewards cross-divisional opportunities and experience in multiple disciplines.
Programs involving cross-training and cross-divisional mobility will provide employees broader
career experiences and enhanced job satisfaction while facilitating more people who have the
essential training and experience in more than one business line to respond to significant events.
The Corporation’s workforce has fallen to approximately 5,300 individuals as of September,
2004. In a continuance of steps in recent years to reduce the size of the workforce, authorized
staffing will additionally be reduced by over 600 positions over the next year or so, resulting in
substantial budget reductions in 2006. This will largely be accomplished through a combination
of buyouts and reductions-in-force (RIF). A Corporation buyout program was approved and
initiated in late 2004 and active planning has begun for RIFs in designated divisions and offices
for late 2005 and 2006.
As the Corporation adjusts to a smaller workforce, it must continue to ensure the readiness of its
staff to carry out the corporate mission. The Corporation has submitted a legislative proposal to
give it increased flexibility in the human resources area to ensure the FDIC can continue to
attract, retain, and reward our high performing employees. Hiring and retaining new talent will
be important, and having hiring and retention policies that are fair and inclusive remains a
significant component of the corporate diversity plan.
OIG Human Capital Actions and Strategies
The OIG is undergoing a similar shift in the way we perceive our organization and our business
with a smaller, more flexible workforce that is aligned with our mission. The OIG took steps
during 2002 in accord with the Chairman’s vision, including major efforts to streamline our
workforce and work processes. The OIG participated in the Corporation’s early retirement and
buyout program and modified our structure to realign OIG operations with the critical business
lines of the FDIC, geographically as well as functionally. This resulted in the separation of 54
employees, or 25 percent of our April 2002 staff level, and the closure of our San Francisco
office during 2002. During 2005, the OIG will participate, on a limited basis, in another
corporate-wide early retirement and buyout program. The OIG plans to have a permanent staff
level of 160 in 2005, compared with the 168 staff authorized for 2004.
While restructuring to a smaller workforce, the OIG continues to look to increasing the value of
our people and the performance capacity of the OIG. Therefore, strategically managing our
human capital will continue to be a top priority in our organization. The OIG issued a Human
Capital Strategic Plan in 2002, which aligns and integrates our human resource policies and
practices with the OIG mission and this is one strategic goal. Our Human Capital Strategic Plan
also complements the other strategic goals by aligning and integrating human resource policies
and practices with our business practices. It also reflects the Chairman’s recent goals of having
the right number of people with the needed skills in the right places. Our human capital plan
focuses on four areas that are key to maximizing the return on our human capital and sustaining a
high-performance organization: workforce analysis; competency investments; leadership
development; and a results-oriented, high-performance culture.
Strengthening our workforce capabilities will be particularly important in the next several years
to prepare and position us for the future in light of our smaller workforce. As part of the Human
Capital Strategic Plan objectives on workforce analysis and competency investments, we have:
Prepared inventories of existing workforce knowledge and workforce knowledge needed, and
identified gaps in knowledge needed to accomplish future work;
Identified and linked competencies needed for every OIG position and aligned them with job
descriptions and position selecting factors;
Developed strategies for closing the identified workforce knowledge gaps, including training,
developmental assignments, recruitment and hiring, and contracting;
Better aligned performance criteria and expectations and rewards/consequences with
accomplishing the OIG strategic mission and goals.
We will continue to evaluate our workforce planning and competency investment strategies.
Skills Requirements
Reviewing FDIC programs and operations requires a staff with a broad range of knowledge,
skills, and abilities. The OIG staff is comprised of auditors, criminal investigators, attorneys,
program analysts, computer specialists, and administrative personnel. This highly professional
staff holds numerous advanced educational degrees and has attained professional certifications,
including certified public accountants, certified internal auditors, and certified fraud examiners.
To maintain professional proficiency, each of our staff attains an average of about 50 hours of
continuing professional education and training annually. OIG staff must also possess and
maintain the necessary skills and abilities of their respective disciplines in order to meet the
unique objectives and challenges of their assignments. For example:
Auditors are required to have knowledge of accounting principles and the methods and
techniques applicable to government auditing; knowledge of government organizations,
programs, activities, and functions they are reviewing; knowledge of applicable statutes and
regulations; and the skills to communicate clearly and effectively, both orally and in writing.
In addition, depending on the type of audit being conducted, auditors may have to possess
knowledge of business, finance, and economics, and of other agencies’ programs as they
relate to the FDIC’s work, as well as skills in research, statistical sampling, information
systems auditing, or other specialized skills as needed.
Criminal investigators are required to have a thorough and current knowledge of federal
criminal procedure and laws concerning search and seizure, arrests, advisement of rights,
surveillance, and the right to privacy - both personal and financial. They should have
knowledge of accounting principles, be proficient at interviewing and eliciting information
from all types of sources, and be able to communicate clearly and effectively, both orally and
in writing. Because of the complex mission of the FDIC, in addition to the traditional skills
associated with their activities, criminal investigators in the FDIC OIG must have significant
knowledge of federal bank regulations and the unique accounting principles associated with
modern financial institution activities. Criminal investigators must be able to react quickly
and appropriately to changing situations and be able to apply their expertise in use-of-force
principles, self-defense, and firearms. The OIG has several agents who are trained as
instructors in defensive tactics and firearms. In addition to their investigative duties, these
agents provide support and advice to our National Training Officer in administering our
training program. The OIG also has an Electronic Crimes Unit, staffed by agents who have
been trained and certified as seized computer evidence specialists.
Analyzing Existing and Needed Workforce Knowledge and Identifying Gaps
The OIG created the OIG Business Knowledge Inventory System (BKIS) in 2003 to analyze
existing business knowledge and skills. This inventory system was created by researching other
efforts in the federal government and through input from the OIG workforce. BKIS enabled the
OIG to create a database of business knowledge of OIG employees and determine where
knowledge gaps existed. After detailed analyses of the results were performed, this information
was provided to individual offices for each to identify potential gaps in knowledge. Major
offices prepared action plans specifying how each planned to address knowledge gaps, e.g.,
formal training, developmental assignments, recruitment, or contracting. The BKIS baseline
data remains available to offices for their use in assessing knowledge and skill gaps. Future
efforts to identify knowledge gaps will involve individual offices identifying gaps and detailing
specific efforts for gap closure.
Integrating Core Competencies into the Human Capital System
Consistent with our Human Capital Strategic Plan, the OIG initiated a multi-year project to
integrate improved core competencies into its Human Capital System. The OIG Competencies
Project identified those skills and behaviors that staff members need to contribute to the overall
mission and goals of the OIG. These core competencies formed the basis of an integrated and
strategically aligned human capital system, which includes:
Position descriptions
Performance management
Individual training and development
Selection and promotions
Organizational development
The OIG Competency Model enabled us to:
Align human resource activities with OIG strategic planning;
Replace outdated performance criteria developed years ago;
Communicate new performance expectations clearly for every employee;
Implement a cornerstone in the Human Capital Strategic Plan around which future efforts,
including a training curriculum will be developed; and
Modernize OIG human resource functions with the best practices of high performance
organizations in government and the private sector.
Six competencies were developed that we believe all OIG staff need to contribute successfully to
the OIG mission and goals. These competencies form the basis for expectations of every OIG
employee, including executives.
Achieves Results. Assumes responsibility and accountability for achieving results in support
of the FDIC and OIG missions and goals.
Communicates Effectively. Effectively communicates orally and in writing to promote
mutual understanding, effective decision-making, and information gathering.
Demonstrates Teamwork. Builds and maintains inclusive, responsive, and constructive
working relationships based on mutual respect and a shared commitment to the OIG’s
mission, values, and goals.
Exhibits Technical Competence. Demonstrates the technical knowledge, skills, and abilities
necessary to effectively carry out the duties and responsibilities of his or her position.
Demonstrates Responsibility and Self-development. Takes personal initiative to improve
individual and organizational performance and promote the OIG’s values and goals, while
exhibiting high standards of professional and ethical behavior and integrity.
Leads Effectively (supervisors only). Creates and maintains a high performance climate
where all employees are challenged and encouraged to achieve excellence.
Each of these competencies was further defined with subsidiary criteria describing the types of
performance included under the competency. Full integration of these core competencies into
the OIG’s human capital system helps develop a greater results-oriented, high performance
culture and enhance accomplishment of OIG strategic goals and objectives.
Information Technology Management and Security
Corporate Environment
Information technology (IT) continues to play an increasingly greater role in every aspect of the
FDIC mission. As corporate employees carry out the FDIC’s principal business lines of insuring
deposits, examining and supervising financial institutions, and managing receiverships, they rely
on information and corresponding technology as an essential resource. Information and analysis
on banking, financial services, and the economy form the basis for the development of public
policies and promote public understanding and confidence in the nation’s financial system. IT is
a critical resource that must be safeguarded.
Accomplishing IT goals efficiently and effectively requires sound IT planning and investment
control processes. The Corporation must constantly evaluate technological advances to ensure
that its operations continue to be efficient and cost-effective and that it is properly positioned to
carry out its mission. Management of IT resources and IT security have been the focus of
several laws, such as the Paperwork Reduction Act, the Government Information Security
Reform Act (GISRA), and most recently, the Federal Information Security Management Act of
2002 (FISMA). Similar to the requirements of GISRA, under FISMA, each agency is required to
report on the adequacy and effectiveness of information security policies, procedures, and
practices and compliance with information security requirements of FISMA.
The Corporation is working to implement many sound information system security controls, and
to fully integrate these into an entity-wide program. Additionally, efforts to identify sensitive
data, plan for and fund essential security measures, incorporate security requirements in FDIC
contracts, enhance software configuration management, and measure the overall performance of
the information security program need continued attention. The FDIC’s Information Security
Strategic Plan provides for a sound information security structure and assures the integrity,
confidentiality, and availability of corporate information assets by proactively protecting them
from unauthorized access and misuse. Additionally, a New Financial Environment project has
analyzed the FDIC’s business needs and will create a financial environment that can best serve
and support the FDIC in the future.
OIG Environment
The OIG has an OIG Information Technology (IT) Strategic Plan that guides internal IT
priorities and ensures efficient and secure uses of IT resources within the OIG. The IT Plan lays
the foundation for identifying, selecting, and using technology to support the goals and
objectives of the Office of Inspector General, especially those goals and objectives detailed in
the OIG’s Strategic Plan and the Human Capital Plan. The goal is to keep the OIG IT Plan
updated and current to ensure that it is responsive in meeting the OIG's IT needs and
requirements to achieve the best possible return on investment.
Our overarching IT goal is to better link information technology planning and investment
decisions to program missions and goals, thus helping ensure that OIG managers and staff have
the IT tools and services they require to successfully and productively perform their work. The
OIG IT vision is to enable our managers and staff, through reliable, secure, and modern
technology, to be more productive and responsive. To help realize the goal and vision, we will
pursue IT solutions that optimize our effectiveness and efficiency, connectivity, reliability, and
security, and serve as a model organization for employing best practices in managing our IT
systems, services, and investments.
Process Improvement: Quality Assurance and Risk Management
The OIG’s value to the FDIC and to the Congress must be based on a foundation of work that is
of the highest quality. Maintaining high standards of quality is essential to achieve the vision,
mission, and goals laid out in this strategic plan, consistent with our core values. Ensuring
quality requires an effective program of risk management to effectively assess and address risks
to the OIG and the FDIC. To continue to ensure and enhance our strategic commitment to
quality and risk management, we are developing a quality assurance framework and a related
enterprise risk management framework.
These complementary initiatives are designed to ensure that our approach to quality and risk
management is comprehensive, transparent, and based on world class best practices. As a result,
OIG governance will be maintained at the highest level and will incorporate mechanisms for
continual improvement.
Quality Assurance Framework
Corporate governance deficiencies in the private sector and related audit quality failures by the
public accounting profession have been well publicized. Within the federal inspector general
community we have promoted increased attention to audit quality as a key mechanism to prevent
similar problems within the public sector. A key aspect was our leadership role in the 2003
update of the Quality Standards for Federal Offices of Inspector General issued by the
President’s Council on Integrity and Efficiency and the Executive Council on Integrity and
Efficiency. These councils, established by executive order, coordinate activities within the OIG
community and establish professional standards.
Building on and incorporating the Inspector General Act and other related laws and standards,
these updated quality standards for federal IGs encompass the broad range of OIG activities and
functions and address: ethics, independence, and confidentiality; professional standards for
audits, inspections, evaluations, and investigations; internal control standards and activities;
internal and external quality assurance programs including peer reviews; strategic and annual
planning and coordination; communicating results of OIG activities; managing human capital;
reviewing legislation and regulations; and receiving and reviewing allegations. Of particular
note, these standards incorporate the 2003 revisions of the Government Auditing Standards
(issued by the Comptroller General of the United States) with which IGs are mandated to comply
under the IG Act. The revisions made significant improvements to the independence standard
applicable to audit work.
Consistent with these quality standards, the OIG is developing a quality assurance framework
that will provide a comprehensive documentation of the mechanisms the FDIC OIG has in place
to ensure that OIG work meets the highest level of quality and provides the highest value to the
FDIC and the Congress.
Enterprise Risk Management Framework
Enterprise risk management (ERM) – the process of identifying and analyzing risk from an
integrated, organization-wide perspective – has been circulating and evolving as a business
concept for several years. It is closely related to the Chief Risk Officer (CRO) concept. The
ERM and CRO concepts have gained additional impetus as a result of corporate governance
problems that have arisen in the private sector that led to the passage of the Sarbanes-Oxley Act
in 2002. Although many organizations are aware of ERM, and various ERM models exist, there
has been no single, commonly accepted definition of risk management and no single, generally
accepted framework on how the process should work.
We believe the ERM concept has applicability to public as well as private sector organizations
and we have initiated work to analyze its applicability to the OIG and FDIC environments.
During this assessment process, we are evaluating various models including, in particular, the
Enterprise Risk Management – Integrated Framework released in September 2004 by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO is
composed of the American Institute of Certified Public Accountants, the American Accounting
Association, Financial Executives International, the Institute of Internal Auditors, and the
Institute of Management Accountants.
Growing out of our assessment, we are developing an enterprise risk management framework for
the OIG that will provide an integrated organization-wide, strategic approach to measuring and
managing all of OIG’s risks in order to (1) maximize the OIG’s value in relation to risks and (2)
provide reasonable assurance that OIG’s mission and strategic goals and objectives will be
achieved. Because of the interrelationship of the OIG risk management and FDIC-wide risk
management, our initiative will necessarily consider the broad FDIC risk management
environment and processes. We expect that the concepts, parameters, and model resulting from
our initiative may be valuable to the Corporation as it continually improves its risk management
programs and practices.
External Factors
The following external factors are beyond the OIG’s control; however, they could significantly
affect the achievement of the goals and objectives in this plan.
Budget
One of the most significant external factors that could affect achievement of our goals is our
budget. Unlike other FDIC divisions and offices, the OIG is subject to the congressional
appropriations process. A significant reduction in our budget would adversely affect the
achievement of our strategic goals and objectives by limiting our ability to review FDIC
programs and activities; respond to allegations of fraud, waste, and abuse; and provide training to
our professional staff.
External Requests
The OIG frequently has to respond to external requests and requirements beyond what is planned
for in our workload and resource estimates. These requests often require immediate response
and shifting of workloads and priorities. Examples include congressional mandates, inquiries,
and requests; Chairman’s and management’s requests; litigation; Freedom of Information Act
and Privacy Act requests; hotline complaints; or other high priority requests for audits,
evaluations, and investigations. These requests can require substantial amounts of time and
resource expenditures, with significant impact on our planned workload. An increase in external
requests above projected levels may have an adverse effect on meeting our planned goals and
objectives.
Resolution of Failing Financial Institutions
Uncertainties in the environment in which financial institutions operate present a challenge to
planning OIG resources and activities. The financial institution environment evolves rapidly,
particularly with the acceleration of interstate banking, new banking products and asset
structures, electronic banking, and consolidations. Also, economic conditions can have a
significant effect on the risk profiles of FDIC-insured financial institutions. For instance, an
economic downturn could result in a higher rate of financial institution failures and an increase
in the inventory of assets to be managed and liquidated by the FDIC. An increase in institution
closings and assets to be liquidated could require the OIG to reallocate resources from planned
program area activities to unplanned receivership management activities. Also, the closing of
institutions increases the risk of fraud, which could affect the workload and allocation of
resources for investigative work. Such factors, which are beyond our control, could hinder the
OIG’s ability to achieve its planned goals.
Emerging Technology
Emerging technology has introduced new ways for insured depository institutions to offer
traditional products and services through new delivery channels and, in some instances, has
fostered development of innovative products and services. Examples of new technology include
Internet banking, e-commerce, e-government, and stored-value card systems. Technological
advancements have influenced the operating strategies of many insured depository institutions
and other providers of financial services as they seek to compete in the increasingly fast-paced
and globally interdependent environment. With technological advancements, particularly the
increased use of electronic banking initiatives, there is a potential risk that fraud and other
inappropriate activity may occur. A reallocation of OIG resources could be needed to ensure that
such risks are appropriately addressed.
Changes in the Financial Services Industry
Over the past 20 years, unprecedented changes have taken place in the financial services industry
that have significantly changed and shaped the environment in which the FDIC and the other
financial regulatory agencies operate. Deposit interest rates have been deregulated, geographic
restrictions have been eliminated, restrictions on permissible activities and products have been
loosened, and the number of insured commercial banks has decreased dramatically. These
changes are being driven by financial modernization, privacy concerns, industry consolidation,
the emergence of new institutions, new trends in borrowing and lending, globalization, and
emerging technology. More major changes for the financial services industry may be in store in
the coming years. The OIG will continue to monitor these changes and other emerging issues as
they develop to ensure they are appropriately addressed through our audits, evaluations, and
investigations. This may require a reallocation of our resources, which could affect the
achievement of the goals and objectives in this plan.
Verification and Validation of Performance Data
Performance data will be verified and validated through the following means:
The System for Tracking Audits and Reports (STAR) tracks information on audit and
evaluation assignments, reports, recommendations, time, and independent public accountant
assignments, and provide managers with reports on those activities. STAR is used to
generate performance measurement data reported under the Results Act as well as provide
statistics for the OIG’s Semiannual Report to the Congress. The data and related reports are
analyzed by OIG staff for accuracy, reasonableness, and completeness. In addition, other
controls such as edit checks and supervisory review of data input are used to ensure the
validity and integrity of the performance data and reports.
The OIG’s Office of Investigations database system was designed specifically, in part, to
more accurately track the measures and goals we have established under the strategic and
annual performance plans. The database system tracks information on investigative cases
opened and closed; fines, restitutions, and other monetary recoveries; and judicial and
administrative actions. We also have an inspection regimen set up to closely monitor the
activities of our investigative offices and to ensure the accuracy of data entered into our
database.
Designated OIG staff will be responsible for collecting, maintaining, and reporting
performance data. Through our performance reports, OIG management will review reported
data for consistency with general performance observations. Each year, we will reevaluate
whether measures are effectively designed and results-oriented. Based on this evaluation, we
will determine whether our performance measures should be revised for the next planning
cycle.
Internal control and quality assurance reviews, performed on a cyclical basis to cover all OIG
functions (audits, investigations, evaluations, and support and administrative activities), will
selectively validate performance data on a test basis, as appropriate, to meet review
objectives.