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AUDIT MEMORANDUM No. 26

September 30, 2002

To: Robert Herdman
Jack Katz
Jim McConnell
Mark Radke
Jayne Seidman

From: Walter Stachnik

Re: Continuity of Operations Planning (COOP)

We performed a survey of the Commission's Continuity of Operations Planning (COOP) in conjunction with an on-going review of the Commission's market contingency preparedness operations. Staff in the Office of Administrative and Personnel Management (OAPM) and the Executive Director's Office (OED) are responsible for ensuring that the Commission's COOP is complete and operational.

National Security Clearances

During our survey, we found that OAPM and OED staff assigned to the Commission's COOP operations did not have a national security clearance. In some instances, this prevented Commission staff from reading classified documents that they contributed to. It also prevented them from engaging in discussions with other Agency staff about possible threats, certain contingency operations and sensitive matters.

Additionally, only staff with national security clearances is generally privy to credible threats received by a Federal Government Agency. This lack of information could prevent a trained COOP staff from reacting timely or properly in an emergency.

Recommendation A

OED, in conjunction with OAPM should (1) review the job requirements of OED and OAPM staff involved in the Commission's COOP, (2) reclassify appropriate job positions as national security for appropriate staff, and (3) obtain national security clearances for the staff in the reclassified positions.

After issuance of the draft memorandum, OED and OAPM senior officials stated that they had reviewed the job requirements of their COOP staff and that, currently, national security clearances are unnecessary for OAPM and OED staff assigned to the Commission's COOP operations. They said they would reclassify job positions as national security and obtain national security clearances for appropriate staff, in the future, if needed.

Submission of COOP Plans

COOP coordinators in OAPM and the OED requested contingency plans from each office and division within the Commission. These plans include contact information for all employees, a listing of essential personnel, lines of succession, calling trees, identification and contact information for key customers and vendors, and identification of key processes and vital records. Each office and division was also asked to provide a written overview of the functions its staff is to perform when a COOP plan is activated.

Some offices have not submitted the requested plans, including the Offices of the Executive Director, the Executive Staff, the Secretary, and the Chief Accountant.

Recommendation B

The Offices of the Executive Director, the Executive Staff, the Secretary and the Chief Accountant should submit requested COOP documents by October 8, 2002¹.

cc: Harry Fleming

Stephen Johnston

Tom McCool

Lisa Panasiti

Darlene Pryor

Dana Schlictmann

¹ The related draft memorandum, dated September 13, 2002, also recommended the submission of these documents.