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Enforcement Administrative Functions
Audit Report No. 233
May 15, 1996
Our review of the Division of Enforcement's administrative
controls found that the controls appeared to provide reasonable
assurance that assets were safeguarded and operations were in
compliance with policies and procedures.
We are making several recommendations to enhance Enforcement's
administrative controls. These include requiring staff to sign
in sequentially by time; reconciling Enforcement's blotter records
with records of the Office of the Comptroller; providing additional
training to the support staff; and improving document storage.
The Division of Enforcement and the Offices of Administrative
and Personnel Management and the Comptroller generally concurred
with our recommendations. Their comments are attached.
OBJECTIVE AND SCOPE
The objective of the review was to determine if Enforcement's
administrative controls were functioning properly and in compliance
with regulations. It covered controls relating to accounting,
time and attendance, travel, property, and training. During
the review, we interviewed Enforcement's administrative staff
and conducted tests of controls.
We did not include procurement within our audit scope. The audit
was performed in accordance with generally accepted government
auditing procedures between July 1995 and January 1996.
The Division of Enforcement, like other offices and divisions,
performs several administrative functions, including maintaining
time and attendance and blotter records, authorizing travel expenditures,
and helping maintain a property inventory. The Division's administrative
staff includes a senior program analyst; administrative assistants;
and numerous clerical and secretarial staff.
Generally, Enforcement's administrative controls appeared to
provide reasonable assurance that assets were safeguarded adequately,
and operations were conducted economically, efficiently, and in
compliance with policies and procedures. Also, its administrative
staff appeared competent and conscientious.
As discussed below, we are recommending several enhancements
to the administrative controls.
In January 1996, the Division implemented sign-in procedures
for employees working an altered schedule, as required by Commission
regulations. However, employees are not recording their arrival
and departure sequentially by time, which weakens the effectiveness
of this control procedure and is contrary to regulations (see
SECHDBK 15-3, page 3). For example, we noted three employees
who by 10:00 a.m. on February 14, 1996 had already signed in and
out. They were able to do this because the log consisted of loose
sheets of paper containing three columns. One column required
the person to sign their name and the other two were for them
to enter the time they arrived and departed.
The Division of Enforcement should require its employees to sign
in and out sequentially in a serial log.
We reviewed overtime documentation for selected 1995 pay
periods for 24 Enforcement employees. We found that the date
and time the overtime was worked was not recorded in all cases
on the overtime approval form (SEC-1749). This information would
allow supervisors to verify overtime (by consulting sign in logs
maintained by the office or division and by the guards), and thus
would help prevent and detect abuse.
The Division of Enforcement should require its employees to document
the date and time of overtime worked on the overtime approval
The Division is not reconciling its blotter records with the
Comptroller's accounting records, as required by Commission regulations
(SECR 14-1). For example, we noted one blotter account, object
code 2530, which had a negative balance ($4,459.08) in fiscal
year 1995 and unrecorded expenses.
Reconciliation helps ensure that financial records are accurate,
prevents over-obligation of funds, and helps managers plan future
The Division of Enforcement should reconcile its blotter records
with the Comptroller's records.
A number of attorneys told us that the support staff could benefit
from paralegal and automation training. Also, several support
staff expressed an interest in this training, and uncertainty
over the basis for training decisions (that is, who receives training).
In consultation with the Office of Administrative and Personnel
Management, the Division of Enforcement should provide additional
paralegal and automation training to its support staff. It should
also clarify the basis for allocating training to its staff.
The Office of Administrative and Personnel Management recently
acquired training materials for users of Commission software.
It has not yet developed procedures for providing these materials
to employees. This software would enable Enforcement to enhance
the staff's abilities. Enforcement's staff cannot always attend
training courses because of sudden changes in their workload.
Enforcement should obtain the training software from OAPM. If
the staff was permitted to use the software they would need to
spend only a few hours a day on training, instead of several days,
as required by most of OAPM sponsored training courses.
The Office of Administrative and Personnel Management should
develop and publicize procedures covering use of its automation
Based on our observations and interviews, the Division's document
storage could be improved. Several offices did not have file
cabinets. Documents were kept in boxes instead. We noted 15 boxes,
some of which were broken, on the floor outside one office. The
documents were not currently needed, according to the staff, and
could have been sent to a temporary storage facility maintained
by a Division contractor. Boxes in the halls constitute a safety
hazard, and should be removed as soon as possible.
The Division of Enforcement should improve its document storage,
for example, by obtaining additional file cabinets and reminding
staff to promptly send unneeded documents to permanent storage.
Per Diem Changes
The Division uses a software package for travel known as
Travel Manager. The Office of the Comptroller updates this software
with per diem changes authorized by the General Services Administration.
The Office of the Comptroller received changes for January
1995 after the month had begun. Consequently, early travel vouchers
for cities with changed per diem rates (for example, San Francisco,
California) used incorrect rates.
The Office of the Comptroller should notify travel coordinators
when updates to Travel Manager are not timely, and indicate which
per diem rates have changed.