Unimplemented Recommendations
The FDIC OIG’s Report on Unimplemented Recommendations, provided at the link below, contains information about recommendations from our audits and evaluations that the OIG has not closed because our office has not determined that the FDIC has fully implemented recommended corrective actions.
Our listing omits recommendations that we determined to be of a sensitive nature, and therefore unsuitable for public release. The status of each recommendation is subject to change due to the FDIC’s ongoing efforts to implement them, and the OIG’s independent review of information about those efforts. Specifically, a recommendation identified as unimplemented in this report may fall into one of several categories:
- within targeted time frames,
- under OIG review, or
- overdue.
Further, the OIG may have subsequently closed a recommendation listed in this report after the date of its issuance.
For each Unimplemented Recommendation listed, we provide the report title, along with a link to the full report if available; the date of report issuance; and a brief description of the recommendation.
Our Unimplemented Recommendations listing will be updated monthly.
Overall Status of Recommendations
FDIC OIG Unimplemented Recommendations as of September 15, 2021
|
OIG Report No. |
Report Title |
Rec No. |
Recommendation |
Issued Date |
|
|---|---|---|---|---|---|
|
1 |
AEC-21-002 |
1 |
Develop and implement defined, objective, quantifiable, and measurable goals related to retention management at the FDIC. |
9/1/2021 |
|
|
2 |
AEC-21-002 |
2 |
Develop and implement a process to collect and analyze the relevant data regarding employee retention across the FDIC and provide the data and analyses to Divisions and Offices. |
9/1/2021 |
|
|
3 |
AEC-21-002 |
3 |
Develop metrics and indicators to assess the effectiveness of the FDIC’s employee retention activities and to determine if the FDIC’s retention activities are achieving their desired results and outcomes. |
9/1/2021 |
|
|
4 |
AUD-17-001 |
5 |
Non-public report. |
11/2/2016 |
|
|
5 |
AUD-20-001 |
2 |
Monitor employee and contractor compliance with policy requirements for properly safeguarding sensitive electronic and hardcopy information. |
10/23/2019 |
|
|
6 |
AUD-20-003 |
3 |
Develop and approve privacy plans for all information systems containing personally identifiable Information consistent with Office of Management and Budget (OMB) Circular A-130. |
12/18/2019 |
|
|
7 |
AUD-20-003 |
5 |
Update policies and/or procedures to reflect the current organizational structure of the Privacy Program and responsibilities of agency personnel and component offices that support the FDIC’s Privacy Program. |
12/18/2019 |
|
|
8 |
AUD-20-003 |
8 |
Develop and implement controls to ensure that personally identifiable Information stored in network shared drives and in hard copy is regularly monitored and reviewed for compliance with privacy laws, regulations, policy, and guidelines. |
12/18/2019 |
|
|
9 |
AUD-21-001 |
3 |
Remediate incomplete and out-of-date baseline configurations. |
10/27/2020 |
|
|
10 |
AUD-21-001 |
4 |
Assess the effectiveness of the FDIC’s controls for managing Administrative Accounts and implement control improvements. |
10/27/2020 |
|
|
11 |
AUD-21-001 |
5 |
Implement a process to ensure that all outsourced information systems are subject to the National Institute of Standards and Technology (NIST) Risk Management Framework as prescribed by Office of Management and Budget (OMB) policy. |
10/27/2020 |
|
|
12 |
AUD-21-001 |
6 |
Ensure that the FDIC’s cloud-based information systems are subject to annual security and privacy control assessments. |
10/27/2020 |
|
|
13 |
AUD-21-002 |
1 |
Reinforce guidance and provide training on the need for effective identification and assessment of information technology project risks, and the prompt and accurate reporting of such risks. |
12/21/2020 |
|
|
14 |
AUD-21-002 |
3 |
Clarify and communicate the roles and responsibilities of Security and Enterprise Architecture Technical Advisory Board and Governance Risk and Compliance Section with respect to security requirements for new technologies. ^ |
12/21/2020 |
|
|
15 |
AUD-21-003 |
Security of Critical Building Services at FDIC-owned Facilities |
2 |
Implement the National Institute of Standards and Technology (NIST) Risk Management Framework for systems supporting critical building services. |
3/29/2021 |
|
16 |
AUD-21-003 |
Security of Critical Building Services at FDIC-owned Facilities |
3 |
Modify the Facilities Management Contract to define security requirements for systems that support critical building services in FDIC-owned facilities. |
3/29/2021 |
|
17 |
AUD-21-003 |
Security of Critical Building Services at FDIC-owned Facilities |
5 |
Ensure that Oversight Managers assigned to other FDIC contracts have obtained signed Confidentiality Agreements for all contractor and subcontractor personnel required to sign such agreements. |
3/29/2021 |
|
18 |
AUD-21-003 |
Security of Critical Building Services at FDIC-owned Facilities |
9 |
Ensure that Oversight Managers assigned to other FDIC contracts have verified the completion of Information Security and Privacy Awareness Training and Insider Threat and Counterintelligence Awareness Training for contractor and subcontractor personnel without network access. |
3/29/2021 |
|
19 |
AUD-21-003 |
Security of Critical Building Services at FDIC-owned Facilities |
10 |
Include a provision in future contracts requiring contractor and subcontractor personnel to complete Insider Threat and Counterintelligence Awareness Training. ^ |
3/29/2021 |
|
20 |
AUD-21-004 |
1 |
Perform a documented assessment of risks associated with Bring Your Own Device and the personal use of Corporate Owned Personally Enabled devices, including the installation and use of mobile applications, text messaging, and audio and video capabilities. |
8/3/2021 |
|
|
21 |
AUD-21-004 |
2 |
Establish mobile device policies and guidance that align with National Institute of Standards and Technology and Government Accountability Office recommended practices. The policies and guidance should (a) reflect the FDIC’s current business practices for mobile devices and (b) be based on the documented assessment of risks in Recommendation 1. |
8/3/2021 |
|
|
22 |
AUD-21-004 |
3 |
Require users of Bring Your Own Devices to consent to rules of behavior in a mobile device security agreement. |
8/3/2021 |
|
|
23 |
AUD-21-004 |
4 |
Define and document roles, responsibilities, and procedures for reviewing audit logs generated by the Mobile Device Management solution. |
8/3/2021 |
|
|
24 |
AUD-21-004 |
5 |
Separate responsibilities for performing systems administration from conducting reviews of audit logs generated by the Mobile Device Management solution. |
8/3/2021 |
|
|
25 |
AUD-21-004 |
6 |
Develop and implement awareness training to address risks and security practices related to the use of mobile devices. |
8/3/2021 |
|
|
26 |
AUD-21-004 |
7 |
Implement a process to routinely report usage information for mobile devices and MiFi devices to business units in the FDIC’s Divisions and Offices. |
8/3/2021 |
|
|
27 |
AUD-21-004 |
8 |
Require the FDIC’s Divisions and Offices to provide End User Computing Section with documentation to support the continued business need for zero usage devices and take action to suspend or terminate unnecessary devices and services. |
8/3/2021 |
|
|
28 |
AUD-21-004 |
9 |
Develop and implement written policies and/or procedures that define roles, responsibilities, and requirements for testing mobile device software updates and documenting the associated results before users are permitted to download and install them. |
8/3/2021 |
|
|
29 |
EVAL-20-001 |
2 |
Provide enhanced contract portfolio reports to FDIC executives, senior management, and the Board of Directors. |
10/28/2019 |
|
|
30 |
EVAL-20-003 |
1 |
Establish, document, and implement policy and procedures for conducting cost benefit analyses, including when and how the cost benefit analyses will be performed. |
2/4/2020 |
|
|
31 |
EVAL-20-003 |
2 |
Establish, document, and implement policy and procedures that clearly define the roles and responsibilities for the Regulatory Analysis Section (RAS), and early involvement for the RAS in participating in and framing the initial policy direction of a rule. |
2/4/2020 |
|
|
32 |
EVAL-20-003 |
3 |
Establish, document, and implement policy and procedures that clearly define the Chief Economist’s roles and responsibilities for reviewing and concurring on cost benefit analyses performed. |
2/4/2020 |
|
|
33 |
EVAL-20-003 |
4 |
Establish, document, and implement policy and procedures that address how cost benefit analyses and supporting information, such as scope and methodology, analyses, conclusions, and reconciliation to the Agency’s final policy decision will be documented and published in the Federal Register to ensure transparency. |
2/4/2020 |
|
|
34 |
EVAL-20-003 |
5 |
Establish, document, and implement policy and procedures for conducting retrospective cost benefit analyses on existing rules, including a regulatory risk assessment, as well as roles and responsibilities for the Driver Divisions, Chief Economist, and Division of Insurance and Research (DIR)/ Regulatory Analysis Section (RAS). |
2/4/2020 |
|
|
35 |
EVAL-20-004 |
5 |
Establish and implement Agency-wide hazard-specific readiness plans, as needed, to identify and integrate FDIC readiness plans and activities unique to specific hazards impacting insured depository institutions. |
4/7/2020 |
|
|
36 |
EVAL-20-007 |
1 |
Clarify criteria the examiners should use to identify an official as dominant. ^ |
9/30/2020 |
|
|
37 |
EVAL-20-007 |
2 |
Train examiners on the importance of understanding and documenting the independence and qualifications of internal auditor(s), and reviewing internal audit work papers and results. |
9/30/2020 |
|
|
38 |
EVAL-20-007 |
3 |
Train examiners on the importance of adequate annual external financial audit coverage, and under what circumstances and with what justifications banks may obtain reviews in place of audits. |
9/30/2020 |
|
|
39 |
EVAL-20-007 |
5 |
Train examiners on the importance of ensuring that information system user access controls be adequately tested. |
9/30/2020 |
|
|
40 |
EVAL-20-007 |
6 |
Enhance case study training to incorporate the lessons learned from Enloe State Bank in regard to performing additional procedures related to the bank’s loan related activity. |
9/30/2020 |
|
|
41 |
EVAL-20-007 |
7 |
Train examiners to perform additional procedures to determine the likelihood of fraud once a dominant official designation is made at a bank with a weak internal control environment. |
9/30/2020 |
|
|
42 |
EVAL-20-007 |
8 |
Train examiners on indicators of fraud and how individual issues identified during an examination should be considered holistically to facilitate fraud detection. |
9/30/2020 |
|
|
43 |
EVAL-21-002 |
1 |
Incorporate the provisions of OMB Policy Letter 11-01 guidance into the FDIC Acquisition Policy Manual (August 2008) and Acquisition Procedures, Guidance and Information document (January 2020). |
3/31/2021 |
|
|
44 |
EVAL-21-002 |
2 |
Identify Critical Functions during the procurement planning, award, and contract management phases of the acquisition process. |
3/31/2021 |
|
|
45 |
EVAL-21-002 |
3 |
Assess whether the FDIC’s Enterprise Risk Management program should identify the impact of procured Critical Functions, and procurement risk related to contractors performing Critical Functions, within the FDIC’s Risk Inventory. ^ |
3/31/2021 |
|
|
46 |
EVAL-21-002 |
4 |
Conduct a procurement risk assessment for Critical Functions during the procurement planning process, for each contract involving Critical Functions. As part of the procurement risk assessment, include a cost effectiveness analysis. |
3/31/2021 |
|
|
47 |
EVAL-21-002 |
5 |
Develop and implement a management oversight strategy for Critical Functions during the procurement planning process, for each contract involving Critical Functions. |
3/31/2021 |
|
|
48 |
EVAL-21-002 |
6 |
Determine the contract structure during the solicitation and award process for the procurement of a Critical Function. |
3/31/2021 |
|
|
49 |
EVAL-21-002 |
7 |
Revise the management oversight strategy for the procured Critical Functions performed under the BOAs for Managed Security Services Provider and Security and Privacy Professional Services to ensure that the strategy aligns with best practices. |
3/31/2021 |
|
|
50 |
EVAL-21-002 |
8 |
Identify missing or insufficient controls in the BOAs and task orders for Managed Security Services Provider and Security and Privacy Professional Services, and implement appropriate corrective actions or compensating controls. |
3/31/2021 |
|
|
51 |
EVAL-21-002 |
9 |
Implement periodic reviews for procured Critical Functions, including for the BOAs and task orders for Managed Security Services Provider and Security and Privacy Professional Services. |
3/31/2021 |
|
|
52 |
EVAL-21-002 |
10 |
Determine when and how to assess for contractor over-reliance as part of the management oversight strategy. |
3/31/2021 |
|
|
53 |
EVAL-21-002 |
11 |
Implement corrective actions when the FDIC determines it is over-reliant on a contractor for a procured Critical Function. |
3/31/2021 |
|
|
54 |
EVAL-21-002 |
12 |
Report to the Board about the Procurement Risk Assessments, Management Oversight Strategies, and contract provisions that address identified risks for planned Critical Functions during the procurement planning phase of the acquisition, for its consideration. |
3/31/2021 |
|
|
55 |
EVAL-21-002 |
13 |
Report to the Board about the Award Profile Reports and corresponding status reports for procured Critical Functions during the contract management phase of the acquisition process on an individual and aggregate contract basis, for its consideration. |
3/31/2021 |
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