Deposit Insurance Funds: Compliance With Obligation and Repayment
Requirements as of 3/31/93 and 6/30/93 (Letter Report, 02/04/94,
GAO/AIMD-94-62).
The Federal Deposit Insurance Corporation's (FDIC) maximum obligation
calculations show that as of March 1993 and June 1993, (1) the Bank
Insurance Fund's (BIF) assets and other funding sources exceeded its
obligations by $41 billion each quarter and (2) the Savings Association
Insurance Fund's (SAIF) assets and other funding sources exceeded its
obligations by $664 million and $636 million, respectively. Nothing
came to GAO's attention that would lead it to question the
reasonableness of the amounts reported for these periods. As of June
1993, neither BIF nor SAIF had borrowed funds for insurance losses from
the U.S. Treasury, although changing economic conditions and other
factors could affect the need for future borrowings. As of June 1993,
FDIC had outstanding about $2.5 billion in borrowings from the Federal
Financing Bank for BIF's working capital needs. FDIC projected that
future net collections from the disposal of BIF's inventory of failed
bank assets would be nearly $16 billion. In August 1993, FDIC repaid
the outstanding balance of BIF's working capital borrowings to the
Federal Financing Bank.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: AIMD-94-62
TITLE: Deposit Insurance Funds: Compliance With Obligation and
Repayment Requirements as of 3/31/93 and 6/30/93
DATE: 02/04/94
SUBJECT: Funds management
Insurance losses
Deposit funds
Bank failures
Authority to borrow from Treasury
Total obligational authority
Insured commercial banks
Savings and loan associations
Government collections
Compliance
IDENTIFIER: Bank Insurance Fund
Savings Association Insurance Fund
BIF
SAIF
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Cover
================================================================ COVER
Report to Congressional Committees
February 1994
DEPOSIT INSURANCE FUNDS -
COMPLIANCE WITH OBLIGATION AND
REPAYMENT REQUIREMENTS AS OF
3/31/93 AND 6/30/93
GAO/AIMD-94-62
Deposit Insurance Funds
Abbreviations
=============================================================== ABBREV
BIF - Bank Insurance Fund
FDI - Federal Deposit Insurance
FDIC - Federal Deposit Insurance Corporation
FDICIA - Federal Deposit Insurance Corporation Improvement Act of
1991
FFB - Federal Financing Bank
FIRREA - Financial Institutions Reform, Recovery, and Enforcement
Act of 1989
FSLIC - Federal Savings and Loan Insurance Corporation
OMB - Office of Management and Budget
RTC - Resolution Trust Corporation
SAIF - Savings Association Insurance Fund
Letter
=============================================================== LETTER
B-251583
February 4, 1994
The Honorable Donald W. Riegle, Jr.
Chairman
The Honorable Alfonse M. D'Amato
Ranking Minority Member
Committee on Banking, Housing,
and Urban Affairs
United States Senate
The Honorable Henry B. Gonzalez
Chairman
The Honorable Jim Leach
Ranking Minority Member
Committee on Banking, Finance
and Urban Affairs
House of Representatives
This is the fourth of our required reports on the Federal Deposit
Insurance Corporation's (FDIC) quarterly compliance with the maximum
obligation limitation established by the Federal Deposit Insurance
Corporation Improvement Act of 1991 (FDICIA). This obligation
limitation applies separately to both the Bank Insurance Fund (BIF),
insurer of commercial bank deposits, and the Savings Association
Insurance Fund (SAIF), insurer of thrift deposits, and is designed to
provide assurance that each fund's assets and other funding sources
are sufficient to fund its obligations. FDIC administers both
insurance funds.
FDICIA also requires us to report on BIF's and SAIF's ability to
repay amounts borrowed from the Department of the Treasury for
insurance losses and to analyze data related to the sale of assets of
failed institutions. As agreed upon with your respective offices,
the latter requirement was modified to include an assessment of
whether BIF's total collections from the management and disposition
of assets acquired from failed institutions would be sufficient to
repay its existing working capital borrowings.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
FDIC's maximum obligation limitation calculations show that as of
March 31, 1993, and June 30, 1993, (1) BIF's assets and other funding
sources exceeded its obligations by $41 billion each quarter and (2)
SAIF's assets and other funding sources exceeded its obligations by
$664 million and $636 million, respectively. Based on our review of
FDIC's calculations and explanatory notes for both BIF and SAIF,
nothing came to our attention that would lead us to question the
reasonableness of the amounts reported as of March 31, 1993, and June
30, 1993. For the first and second quarters of calendar year 1993,
FDIC allocated the entire amount of Treasury borrowing authority to
BIF based on BIF's projected funding needs when funding legislation
was first proposed.
As of June 30, 1993, neither BIF nor SAIF had borrowed funds for
insurance losses from the U.S. Treasury. The need for future
borrowings for insurance losses, and each fund's ability to repay any
such borrowings, depends on the impact of future economic conditions
on financial institution failures, the cost of these failures to the
insurance funds, future assessment revenues, and other funding
alternatives. Currently, FDIC anticipates that BIF will not need to
borrow funds from Treasury to cover insurance losses through fiscal
year 1998, and that BIF will achieve its designated ratio of reserves
to insured deposits of 1.25 percent by 1998. Additionally, the
Resolution Trust Corporation Completion Act, by extending the
Resolution Trust Corporation's authority to resolve troubled thrifts
and providing it with the necessary funding for its resolution
activities, should reduce the likelihood that SAIF will need to
borrow funds from Treasury to cover insurance losses in the near
future.
As of June 30, 1993, FDIC had outstanding approximately $2.5 billion
in borrowings from the Federal Financing Bank (FFB) for BIF's working
capital needs. FDIC estimated that net future collections from the
management and disposition of BIF's June 30, 1993, inventory of
failed bank assets would be about $15.9 billion. On August 6, 1993,
FDIC repaid the outstanding FFB balance of BIF's working capital
borrowings.
BACKGROUND
------------------------------------------------------------ Letter :2
Section 15(c) of the Federal Deposit Insurance (FDI) Act, as amended
by FDICIA, requires that FDIC determine the limitation on outstanding
obligations for BIF and SAIF based on a maximum obligation limitation
formula. In general, the formula involves comparing the assets and
liabilities of each of the two insurance funds to ensure that at any
point in time, each fund's assets are sufficient to cover its
liabilities. The obligation limitation precludes FDIC from issuing
or incurring obligations for BIF or SAIF if, after doing so, total
outstanding obligations of each fund, considered separately, would
exceed the sum of its available funding sources. The obligation
formula is designed to provide assurance that the obligations of each
fund are adequately supported by its assets and available funding
sources and to alert the Congress to FDIC's funding needs.
FDICIA defines funding sources for each fund as (1) its cash and cash
equivalents, (2) the amount equal to 90 percent of the fair market
value of its assets other than cash and cash equivalents, and (3) its
allocated portion of the total amount authorized to be borrowed from
Treasury under section 14(a) of the FDI Act, as amended by FDICIA.
Section 14(a) of the FDI Act, as amended by FDICIA, provided FDIC
with $30 billion in borrowing authority with Treasury to cover
insurance losses. The borrowing authority is available for both BIF
and SAIF, but FDICIA does not specify how the $30 billion should be
allocated between the two funds. In defining obligations, the act
requires that FDIC identify all guarantees (excluding deposit
guarantees), any amounts borrowed from Treasury or FFB pursuant to
section 14 of the FDI Act, and any other obligations for which the
funds have a direct or contingent liability.\1
--------------------
\1 As agreed to by the Senate and House Banking Committees, FDIC's
estimated liability for future financial institution failures or
assistance transactions is excluded in determining each fund's total
obligations where there is no contractual agreement between FDIC and
the troubled institutions comprising the estimated liability.
OBJECTIVES, SCOPE, AND
METHODOLOGY
------------------------------------------------------------ Letter :3
The objectives of this review were to determine whether (1) BIF and
SAIF have complied with the statutory maximum obligation limitation
specified in FDICIA for the quarters ending March 31, 1993, and June
30, 1993, (2) BIF and SAIF have borrowed from the U.S. Treasury for
insurance losses and what factors may affect the need for future
borrowings, as well as BIF's and SAIF's ability to meet established
repayment schedules when borrowings occur, and (3) BIF will generate
sufficient proceeds from the management and disposition of failed
bank assets to repay working capital borrowings. See appendix I for
details on the scope and methodology of our work.
We performed our work at FDIC's headquarters offices in Washington,
D.C., and Arlington, Virginia, from September through November 1993.
We performed our work in accordance with generally accepted
government auditing standards. However, the scope of our work was
substantially less than that of a financial audit and, as such, did
not include a review of FDIC's internal control structure. Also, we
did not test or verify FDIC's books and records or the data contained
in appendixes II and III, except for the procedures detailed in
appendix I. Our review of compliance with laws and regulations was
limited to BIF's and SAIF's compliance with the maximum obligation
limitation established by FDICIA. While we did not obtain written
comments on this report, we discussed its contents with cognizant
FDIC officials and have incorporated their comments where
appropriate.
FDIC REPORTS BIF AND SAIF
COMPLIED WITH THEIR MAXIMUM
OBLIGATION LIMITATIONS
------------------------------------------------------------ Letter :4
FDIC's maximum obligation limitation calculations for BIF and SAIF
show that as of March 31, 1993, and June 30, 1993, BIF's assets and
other funding sources exceeded its obligations by $41 billion each
quarter, and SAIF's assets and other funding sources exceeded its
obligations by $664 million and $636 million, respectively. This
excess is described in the calculations as "Remaining Obligation
Authority." The obligation limitation calculations and explanatory
notes for BIF and SAIF are included as appendixes II and III,
respectively.
Based on our review of FDIC's first and second quarter 1993
calculations and explanatory notes for BIF and SAIF, nothing came to
our attention that would lead us to question the reasonableness of
the amounts reported.
ALLOCATION OF TREASURY
BORROWING AUTHORITY
---------------------------------------------------------- Letter :4.1
In our report on FDIC's compliance with FDICIA's obligation and
repayment requirements as of September 30, 1992, and December 31,
1992,\2 we noted that FDIC had not finalized a policy for allocating
Treasury borrowing authority between BIF and SAIF. This condition
persisted through June 30, 1993. As in each quarter of 1992, FDIC
allocated all $30 billion of its Treasury borrowing authority to BIF
for the first and second quarters of 1993 based on projections of
BIF's funding needs when funding legislation was first proposed. At
that time, projections of bank failures and their cost to the
insurance fund indicated that BIF would need about $30 billion to
cover insurance losses.
FDIC amended its statement of accounting policy for calculating the
maximum obligation limitation in August 1993 to incorporate guidance
on how to allocate Treasury borrowing authority. Under this
guidance, Treasury borrowing authority will be allocated based on
funding needs identified in recapitalization schedules FDIC prepares
for BIF and SAIF. FDIC prepares these schedules semiannually when it
proposes the semiannual assessment rates to be charged to insured
institutions. According to the guidance in the amended policy
statement, any Treasury borrowing authority exceeding projected
funding needs identified in the recapitalization schedules will be
allocated based on the proportion of the insured deposit base of each
fund to the total combined deposit base of the two funds. In
addition, any alternative funding source already committed at the
time the maximum obligation limitation calculation is made will be
factored into the allocation process.
--------------------
\2 Deposit Insurance Funds: Compliance with Obligation and Repayment
Requirements as of 9/30/92 and 12/31/92 (GAO/AIMD-93-75, September
30, 1993).
SEVERAL FACTORS WILL AFFECT
FDIC'S TREASURY BORROWING NEEDS
------------------------------------------------------------ Letter :5
To date, FDIC has not borrowed funds from Treasury to cover insurance
losses for either BIF or SAIF. The timing and extent to which such
funding may be needed will depend on a number of factors, including
(1) the effect of future economic conditions on financial institution
failures and the cost of these failures to the insurance funds, (2)
future revenue streams available to the funds, and (3) the impact of
recent legislation. These factors will also affect FDIC's ability to
rebuild the insurance funds' reserves to designated levels.
FDICIA prohibits Treasury borrowing unless Treasury and FDIC have an
agreement which provides a repayment schedule and demonstrates that
income for BIF or SAIF will be sufficient to repay principal and
interest on Treasury borrowings within the period established in the
repayment schedule. Separate agreements must be established for BIF
and SAIF.
According to the recent cash flow projections FDIC submitted to the
Office of Management and Budget (OMB), FDIC does not anticipate that
BIF will need to borrow from Treasury for insurance losses through
fiscal year 1998. FDIC has cautioned that its projections of
financial institution failures are subject to variables beyond its
control and that the reliability of the projections declines as the
time period covered by the forecast increases. For example, FDIC's
cash flow projections are influenced in part by changes in economic
conditions and fluctuations in interest rates. These factors can
affect the timing of financial institution failures and the closure
of institutions by the regulators.
FDIC also considers assessment revenues in projecting its borrowing
needs. For premiums due in the semiannual period beginning on
January 1, 1993, and thereafter, FDIC adopted a risk-based premium
system. Under this system, banks and thrifts posing higher risks of
loss to the insurance funds are charged higher premiums. The
assessment rates charged to federally insured institutions range from
23 cents to 31 cents per $100 of domestic deposits. Recent FDIC
estimates show the average assessments charged to BIF-insured
institutions to be 24.3 cents per $100 of domestic deposits, an
increase of about 6 percent over the assessment rate of 23 cents per
$100 of domestic deposits in effect through calendar year 1992.
FDIC's estimates show the average assessments charged to SAIF-insured
institutions to be 24.8 cents per $100 of domestic deposits, an
increase of about 8 percent over the assessment rate of 23 cents per
$100 of domestic deposits charged in 1992.
As of the date of this report, FDIC had not submitted revised cash
flow projections for SAIF to OMB to reflect changes resulting from
recent legislation. SAIF was scheduled to assume full responsibility
for resolving troubled thrifts from the Resolution Trust Corporation
(RTC) on October 1, 1993.\3
However, the Resolution Trust Corporation Completion Act (Public Law
103-204, enacted on December 17, 1993) extends RTC's resolution
authority and provides RTC additional funding to resolve troubled
thrifts identified by the Office of Thrift Supervision. The act also
modifies SAIF's available sources of funding for insurance losses.
Specifically, the act extends RTC's resolution authority through a
date to be determined by the Chairman of the Thrift Depositor
Protection Oversight Board but no earlier than January 1, 1995, and
no later than July 1, 1995.\4 The act also restores to RTC through
December 31, 1995, $18.3 billion to resolve troubled thrifts.\5
Additionally, the act amends section 11(a) of the FDI Act by
authorizing up to $8 billion to SAIF to cover losses incurred by SAIF
in fiscal years 1994 through 1998. However, prior to receiving such
funds, FDIC must certify, among other things, that SAIF is unable to
cover its losses through insurance premiums or through available
Treasury borrowing without adversely affecting the health of its
member institutions and thus causing the government to incur greater
losses. The act also makes available to SAIF, upon RTC's December
31, 1995, termination and through December 31, 1997, any of the $18.3
billion in appropriated funds not used by RTC. As with the $8
billion, FDIC must first certify that SAIF cannot fund its incurred
losses through industry premium assessments or Treasury borrowings
without adversely affecting the health of its member institutions and
causing the government to incur greater losses.
--------------------
\3 The Financial Institutions Reform, Recovery, and Enforcement Act
of 1989 (FIRREA) established RTC to resolve thrifts whose deposits
had been insured by the Federal Savings and Loan Insurance
Corporation (FSLIC) that were placed into conservatorship or
receivership from January 1, 1989, through August 8, 1992. The
Resolution Trust Corporation Refinancing, Restructuring, and
Improvement Act of 1991 (Public Law 102-233), enacted on December 12,
1991, extended RTC's resolution authority to thrifts placed into
conservatorship or receivership through September 30, 1993.
\4 However, any thrift requiring resolution after the expiration of
RTC's resolution authority which had previously been under RTC
conservatorship or receivership may be transferred back to RTC for
resolution. Through the expiration of RTC's resolution authority,
SAIF is responsible for the resolution costs of any federally insured
thrift that was not previously insured by FSLIC. Additionally, SAIF
may also incur resolution costs related to certain other institutions
prior to assuming full resolution responsibility. Section 5(d)(3) of
the FDI Act, as amended by FIRREA, generally allows bank holding
companies to merge their SAIF-insured subsidiaries into their
BIF-insured bank subsidiaries. The resulting banks would continue to
pay a portion of their premiums to SAIF based on the amount of thrift
deposits acquired. Accordingly, in the event of failure or
assistance, any loss would be allocated between BIF and SAIF in
proportion to the institution's deposits insured by each fund.
FDICIA expanded on the FIRREA amendment to allow an insured bank or
thrift to acquire, merge, or assume the deposit liabilities of the
other type of insured depository institution. As with the FIRREA
amendment, insurance premiums and loss expenses are to be allocated
between BIF and SAIF.
\5 The act amends section 21A(i) of the Federal Home Loan Bank Act by
removing the April 1, 1992, deadline for obligating $25 billion
provided to RTC by Public Law 102-233 for resolution activity.
Through April 1, 1992, RTC had obligated $6.7 billion of the $25
billion.
SIMILAR FACTORS COULD AFFECT
EFFORTS TO REBUILD THE
INSURANCE FUNDS
---------------------------------------------------------- Letter :5.1
Resolution costs and assessment revenues are also significant factors
to be considered in projecting BIF's and SAIF's future fund balances.
In an effort to achieve a level of self-sufficiency, FDICIA requires
FDIC to develop a recapitalization plan for BIF that specifies target
ratios of reserves to insured deposits at semiannual intervals,
culminating in a reserve ratio equal to the designated 1.25 percent
reserve ratio in no more than 15 years.
At June 30, 1993, FDIC reported that BIF had an unaudited fund
balance of $6.8 billion. The most recent FDIC projections contained
in FDIC's revised BIF recapitalization schedule show that BIF will
achieve the designated ratio by the year 1998, within the 15-year
period stipulated in FDICIA. However, these projections are subject
to significant uncertainties. Forecasting bank failures and their
costs to BIF over the long term is a highly imprecise process.
Additionally, assumptions about the level of bank failures, growth in
industry assets and insured deposits, and BIF's assessment revenues
over extended periods are subject to considerable fluctuations due to
future economic conditions, further industry consolidation, and the
implementation of regulatory reforms mandated by FDICIA.
Section 7(b) of the FDI Act also establishes SAIF's designated
reserve ratio at 1.25 percent of estimated insured deposits and
stipulates that this ratio is to be achieved within a "reasonable
period of time." As of June 30, 1993, FDIC reported that SAIF had an
unaudited fund balance of $638 million, making its ratio of reserves
to insured deposits negligible. However, the Resolution Trust
Corporation Completion Act's extension of RTC's resolution authority
and restoration of funds to enable it to resume resolution of
troubled thrifts, coupled with FDIC's risk-based premium system,
should assist in building SAIF's reserves, subject to future economic
conditions and other factors affecting the health of institutions for
which SAIF currently has resolution responsibility.
FDIC REPAID WORKING CAPITAL
BORROWINGS DURING 1993
------------------------------------------------------------ Letter :6
FDIC has authority to borrow funds for BIF's working capital needs
from FFB, but the amount of its outstanding working capital
borrowings is subject to BIF's maximum obligation limitation. As of
June 30, 1993, BIF had outstanding approximately $2.5 billion in FFB
borrowings. On the basis of its historical collection experience,
FDIC estimated that BIF's net future collections from the liquidation
of its asset inventory at June 30, 1993, should equal about $15.9
billion.\6
We reviewed FDIC's calculation for estimating future collections and
nothing came to our attention that caused us to question the
reasonableness of FDIC's methodology.
During 1992 and 1993, conditions in the banking industry improved,
resulting in substantially fewer bank failures than in recent years
and, consequently, in lower disbursements to fund resolution
activity. At the same time, BIF's funding from the liquidation of
assets from its failed institution asset inventory and from its
premium assessments increased. As a result, on August 6, 1993, FDIC
repaid BIF's outstanding FFB borrowings of $2.5 billion.
Additionally, FDIC's recent cash flow projections submitted to OMB
indicate that FDIC does not anticipate the need to borrow from FFB
for BIF's working capital needs in the next 5 years. As noted
earlier, however, the reliability of such projections declines as the
time period covered by the forecast increases.
--------------------
\6 FDIC's analysis and estimates did not address when recoveries
would occur. As discussed in our previous maximum obligation
limitation reports, estimates of future recoveries derived from
historical collection experience are subject to significant
uncertainties.
---------------------------------------------------------- Letter :6.1
We are sending copies of this report to the Acting Chairman of the
Board of Directors, Federal Deposit Insurance Corporation; the
Director, Office of Management and Budget; and the Secretary of the
Treasury.
Please contact me at (202) 512-9406 if you or your staffs have any
questions concerning the report. Other major contributors are listed
in appendix IV.
Robert W. Gramling
Director, Corporate Financial Audits
SCOPE AND METHODOLOGY
=========================================================== Appendix I
To determine whether BIF and SAIF complied with the statutory maximum
obligation limitation specified in FDICIA for the quarters ending
March 31 and June 30, 1993, we reviewed the completeness and
reasonableness of the components and explanatory notes in FDIC's
first and second quarter calendar year 1993 maximum obligation
limitation reports for BIF and SAIF. For this review, we performed
procedures more limited in scope than those conducted in an actual
financial statement audit of the insurance funds. For example, we
only reviewed the activity that occurred in the first and second
quarters of 1993. To obtain assurance as to the reasonableness of
first quarter 1993 opening balances, we relied on the results of the
audit procedures performed on the December 31, 1992, balances in our
1992 BIF and SAIF financial audits.\1 We believe our procedures
provide us with sufficient assurance to draw conclusions regarding
FDIC's first and second quarter 1993 compliance with its maximum
obligation limitation.
Our review work included the following.
We compared the components of FDIC's maximum obligation limitation
calculations for BIF and SAIF to the provisions of FDICIA and to
each fund's March 31, 1993, and June 30, 1993, Statement of
Financial Position and corporate general ledger trial balance.
We performed analytical procedures on the individual accounts that
comprised each of the maximum obligation limitation
calculation's line item components to identify (1) the dollar
and percentage change in the account balances from December 31,
1992, to March 31, 1993, and from March 31, 1993, to June 30,
1993, and (2) any unusual account balances.
We developed criteria to identify accounts that required detailed
review procedures. These criteria considered the account's
materiality as it relates to the balance of the line item in
which it is grouped, and the extent to which the account balance
changed from quarter to quarter. For accounts meeting these
criteria, we performed the following additional procedures: (1)
obtained explanations for any large or unusual fluctuations in
the account balances from appropriate FDIC officials, (2)
obtained and reviewed supporting documentation for those
accounts exhibiting large or unusual fluctuations for which FDIC
officials did not provide sufficient explanation, (3) obtained
and reviewed account reconciliations for specific accounts and
verified the adequacy of these reconciliations, (4) confirmed
balances for specific accounts, and (5) selected a judgmental
sample of transactions for certain accounts and traced these
transactions to supporting documentation.
To determine whether BIF and SAIF had borrowed from the U.S.
Treasury for insurance losses, what factors may affect the need for
future borrowings, and whether BIF and SAIF will be able to meet
established repayment schedules, we reviewed the status of FDIC
borrowings from Treasury as of June 30, 1993. We also discussed
anticipated borrowing needs with FDIC officials and reviewed FDIC's
most recent projections of potential funding needs for BIF and SAIF.
To determine whether BIF will generate sufficient proceeds from the
management and disposition of failed bank assets to repay working
capital borrowings, we gained an understanding of FDIC's collection
processes. We reviewed FDIC's estimates of future collections, which
were based on FDIC's historical experience in generating funds for
BIF from the management and disposition of assets acquired from
failed financial institutions through June 30, 1993. As agreed upon
with your respective offices, our work was limited to an analysis of
FDIC's historical collection experience to determine whether FDIC can
generate sufficient funds for BIF from the management and disposition
of failed bank assets to repay the Fund's existing working capital
borrowings; we did not audit the collection and loss information
provided.
(See figure in printed edition.)Appendix II
--------------------
\1 Financial Audit: Federal Deposit Insurance Corporation's 1992 and
1991 Financial Statements (GAO/AIMD-93-5, June 30, 1993).
BIF MAXIMUM OBLIGATION LIMITATION
CALCULATION AND NOTES AS OF MARCH
31 AND JUNE 30, 1993
=========================================================== Appendix I
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)Appendix III
SAIF MAXIMUM OBLIGATION LIMITATION
CALCULATION AND NOTES AS OF MARCH
31 AND JUNE 30, 1993
=========================================================== Appendix I
(See figure in printed edition.)
(See figure in printed edition.)
(See figure in printed edition.)
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV
ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C.
Steven J. Sebastian, Assistant Director
Michael C. Hrapsky, Audit Manager
Elizabeth Martinez, Senior Auditor
Dennis L. Clarke, Senior Auditor
OFFICE OF GENERAL COUNSEL
Jeffrey A. Jacobson, Assistant General Counsel
Helen Desaulniers, Attorney