Federal Reserve Banks: Internal Control, Accounting, and Auditing Issues
(Letter Report, 02/09/96, GAO/AIMD-96-5).

GAO's work at the Federal Reserve Bank of Dallas, its three branches,
and the Federal Reserve Automation Services has found internal control
issues significant enough to warrant management's attention. These
issues include how (1) the accounting records of the Dallas Federal
Reserve Bank and its branches are reconciled, reviewed, maintained, and
reported on; (2) accountability over assets is maintained; and (3)
automated systems are used by the Dallas Federal Reserve Bank and its
branches. GAO also identified an opportunity for the Federal Reserve to
improve the consistency and the efficiency of its note-accounting
procedures. The Board has contracted with a public accounting firm for
annual audits of the Federal Reserve Banks' combined financial
statements for each of the next five years. The firm is also required to
audit each of the individual Federal Reserve Banks once during this
period. GAO concurs in this audit strategy. The auditor, however, faces
significant challenges arising from (1) the lack of independent parties
to confirm the ownership and the original cost of U.S. Treasury
securities, which results from the Federal Reserve Banks' unique role as
Treasury's fiscal agent; (2) the impossibility of confirming amounts
held by hundreds of millions of note holders; and (3) the notes' unusual
characteristics (for example, they never mature or expire and can be
destroyed by events not under the control of the Federal Reserve Banks).

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-96-5
     TITLE:  Federal Reserve Banks: Internal Control, Accounting, and 
             Auditing Issues
      DATE:  02/09/96
   SUBJECT:  Federal reserve banks
             Financial statement audits
             Internal controls
             Computer security
             Financial records
             Accounting procedures
             Auditing standards
             Federal agency accounting systems
             Data integrity
             ADP
IDENTIFIER:  Dallas (TX)
             El Paso (TX)
             Houston (TX)
             San Antonio (TX)
             New York (NY)
             
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Cover
================================================================ COVER


Report to the Ranking Minority Member, Committee on Banking and
Financial Services, House of Representatives

February 1996

FEDERAL RESERVE BANKS - INTERNAL
CONTROL, ACCOUNTING, AND AUDITING
ISSUES

GAO/AIMD-96-5

Federal Reserve Banks

(917760)


Abbreviations
=============================================================== ABBREV

  EDP - electronic data processing
  FRAS - Federal Reserve Automation Services
  FRB - Federal Reserve Bank
  GAAS - generally accepted auditing standards
  GAGAS - generally accepted government auditing standards

Letter
=============================================================== LETTER


B-265899

February 9, 1996

The Honorable Henry B.  Gonzalez
Ranking Minority Member, Committee on Banking
 and Financial Services
House of Representatives

Dear Mr.  Gonzalez: 

Based upon your request and discussions with your staff, we agreed to
audit the Federal Reserve Bank (FRB) of Dallas to address your
concerns about the lack of independent financial statement audits of
the FRBs.  After we began our work, the Board of Governors of the
Federal Reserve System contracted for external, independent audits of
the combined financial statements of the FRBs for each of the next 5
years.  We commend the Board for taking this step and believe that
instituting regular, external independent audits will help enhance
accountability over the operations of the Federal Reserve System. 
Additionally, this step places the United States on a par with the
practices of other central banks, such as those in France, Germany,
and the United Kingdom. 

The purpose of this report is to summarize the results of our work
related to the Dallas FRB.  During our audit we (1) identified and
communicated to Federal Reserve officials various weaknesses and
suggested corrective actions related to financial accounting and
reporting controls and electronic data processing (EDP) general
controls that warranted management's attention, (2) found an
opportunity to improve the efficiency and consistency of Federal
Reserve note accounting, for which we are making recommendations to
the Board, and (3) identified auditing issues that need the attention
of the Board and its auditor because the auditor cannot fully rely on
traditional audit procedures to substantiate the FRBs' largest assets
(U.S.  Treasury securities) and liabilities (Federal Reserve notes,
the nation's paper currency). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Our work at the Dallas FRB, its three branches, and the Federal
Reserve Automation Services (FRAS) identified internal control issues
that we considered significant enough to warrant management's
attention.  These issues included how (1) the accounting records of
the Dallas FRB and its branches are reconciled, reviewed, maintained,
and reported, (2) accountability over assets is maintained, and (3)
automated systems are utilized by the Dallas FRB and its branches,
many of which are controlled by FRAS.  Our findings were reported to
officials of the Dallas FRB\1 and FRAS,\2 as applicable.  In these
reports, we provided suggestions for improvements and documented the
many corrective actions Dallas FRB and FRAS officials have taken to
date. 

During the audit, we also found an opportunity for the Federal
Reserve to improve the consistency and efficiency of its note
accounting procedures.  The FRBs have historically accounted for
notes issued based on the FRB identifier imprinted on the face of
each note.  However, each FRB's reported net liability balance for
notes does not reflect the notes in circulation bearing its unique
identifier, as the financial statements imply.  Changes in the
Federal Reserve Act have eliminated the provisions that gave rise to
this long-standing accounting practice.  Continuing to use these
identifiers as the basis for recording note liabilities appears to be
unnecessary and inefficient. 

The Board has contracted with a public accounting firm for annual
audits of the FRBs' combined financial statements for each of the
next 5 years.  Additionally, the firm is required to audit each of
the individual FRBs once during this period.  We concur with this
overall audit strategy, which focuses on the combined financial
statements.  The auditor will face significant challenges, arising
principally from (1) the lack of independent parties to confirm the
ownership and original cost of U.S.  Treasury securities, which
results from the FRBs' unique role as Treasury's fiscal agent, (2)
the impossibility of confirming amounts held by the hundreds of
millions of note holders, and (3) the notes' unusual characteristics
(for example, they never mature or expire and can be destroyed by
events the FRBs cannot control). 


--------------------
\1 Dallas FRB Internal Controls (GAO/AIMD-96-31R, January 18, 1996). 

\2 FRAS General Controls (GAO/AIMD-96-32R, January 18, 1996). 


   BACKGROUND
------------------------------------------------------------ Letter :2

The Federal Reserve System was created by the Federal Reserve Act in
1913 as the central bank of the United States to provide a safe and
flexible banking and monetary system.  The System is composed
primarily of 12 FRBs with 25 branches (organized into 12 districts),
the Federal Open Market Committee, and the Federal Reserve Board,
which exercises broad supervisory powers over the FRBs. 

The primary functions of the Federal Reserve System are to (1)
conduct the nation's monetary policy by influencing bank reserves and
interest rates, (2) administer the nation's currency in circulation,
(3) buy or sell foreign currencies to maintain stability in
international currency markets, (4) provide financial services such
as check clearing and electronic funds transfer to the public,
financial institutions, and foreign official institutions, (5)
regulate the foreign activities of all U.S.  banks and the domestic
activities of foreign banks, and (6) supervise bank holding companies
and state chartered banks that are members of the System.  The FRBs
also provide various financial services to the U.S.  government,
including the administration of Treasury securities. 

The FRBs' assets are comprised primarily of investments in U.S. 
Treasury and agency securities.  As of December 31, 1994, the FRBs
reported a securities portfolio balance of $379 billion (87 percent
of total assets).  These securities primarily consist of Treasury
bills, Treasury notes, and Treasury bonds that the FRBs buy and sell
when conducting monetary policy.  The FRBs act as Treasury's fiscal
agent by creating Treasury securities in electronic (book-entry) form
upon authorization by the U.S.  Treasury and administering ongoing
principal and interest payments on these securities. 

Treasury securities are maintained on electronic recordkeeping
systems operated and controlled by the FRBs.  The U.S.  Treasury
maintains an independent record of total Treasury securities
outstanding but not individual ownership records.  The FRBs maintain
records of securities held by depository institutions, by the central
banks of other countries, and which they hold for their own account. 
These records do not indicate whether securities held by the
depository institutions are for their own accounts or on behalf of
their customers.  The portion of these securities owned by the FRBs
is maintained on recordkeeping systems that the New York FRB
operates. 

A security's historical cost is comprised of the security's face
value (par) and any difference between this face value and the
security's purchase price.  These differences are referred to as
premiums when the purchase price is higher than the face value and as
discounts when the price is less than the face value.  These amounts
are reduced over the life of the security to adjust interest income. 

Federal Reserve notes are the primary paper currency of the United
States in circulation and the FRBs' largest liability.  As of
December 31, 1994, the FRBs reported a Federal Reserve note balance
of $382 billion (89 percent of total liabilities).  Notes are printed
by the U.S.  Treasury's Bureau of Engraving and Printing and shipped
to the FRBs, who store them in their vaults until they are withdrawn
by financial institutions.  Notes do not mature or expire and are
liabilities of the FRBs until they are returned to the FRBs.  The
amount the FRBs report as their liabilities for outstanding notes is
actually a running balance of all notes issued from inception that
have not been returned to the FRBs. 

The Federal Reserve Act designates certain assets of each FRB as
eligible collateral for the reported Federal Reserve note liability. 
The majority of the assets pledged as collateral are each FRB's
Treasury securities.  In addition, the FRBs have entered into
cross-collateralization agreements under whose terms the assets
pledged as collateral to secure each FRB's notes are also pledged to
secure the notes of all the FRBs.  Therefore, as long as total
collateral assets held by the FRBs equal or exceed the FRBs' total
liabilities for notes, the note liability of each individual FRB is
fully secured. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

To conduct our work, we (1) gained an understanding of relevant
accounting and reporting policies and procedures by reviewing and
analyzing documentation and interviewing key FRB and Board personnel,
(2) reviewed documentation supporting selected significant balance
sheet amounts originating at the Dallas FRB, and (3) tested the
effectiveness of certain internal controls in place at the Dallas FRB
and the Federal Reserve Automation Services (FRAS) in Richmond,
Virginia, and Dallas, Texas. 

We conducted our work primarily at the Federal Reserve Banks of
Dallas and New York; the Dallas FRB's branches in Houston, San
Antonio, and El Paso; the two FRAS sites mentioned above; and the
Board of Governors of the Federal Reserve System in Washington, D.C.,
between July 1994 and November 1995 in accordance with generally
accepted government auditing standards. 

We requested written comments on a draft of this report from the
Chairman, Board of Governors of the Federal Reserve System.  The
Secretary of the Board provided us with written comments.  These
comments are discussed in the "Agency Comments and Our Evaluation"
section and are reprinted in appendix I. 


   DALLAS FRB'S AND FRAS' INTERNAL
   CONTROLS CAN BE STRENGTHENED
------------------------------------------------------------ Letter :4

Our work at the Dallas FRB, its three branches, and the Federal
Reserve Automation Services identified internal control issues that
we considered to be significant enough to warrant management's
attention.  Our findings were detailed in separate reports to
officials of the Dallas FRB and FRAS, as applicable.\3 In these
reports, we provided suggestions for improvements and documented the
many corrective actions either taken, underway, or planned by Dallas
FRB and FRAS officials. 

The issues we identified at the Dallas FRB include weaknesses in
controls over financial reporting, those aspects of automated systems
that were controlled in Dallas, check processing, and Federal Reserve
note inventories.  For example, (1) reconciliations of general ledger
accounts and activity were not always based on independent records,
(2) the automated systems did not prohibit access by all terminated
employees, (3) accounting adjustments related to check processing
activity were not appropriately reviewed, and (4) inventory counts of
Federal Reserve notes at some branches were not always properly
conducted and documented.  The management of the Dallas FRB has
already taken action on some of our suggestions to resolve these
issues. 

We also identified weaknesses in general controls\4 over the
automated systems maintained and operated by FRAS and used by the
Dallas FRB.  These weaknesses involved controls over access to
sensitive information and the computer center, changes to system
software, testing the disaster recovery plan, and the use of special
privileges on automated tasks.  For example, (1) access to job
management software was not restricted to authorized individuals, (2)
access to the FRAS computer center was inappropriately granted to
contractor personnel, (3) FRAS lacked policies and procedures for
testing and certifying software changes prior to implementation, and
(4) FRAS had not tested the communication network linking the Federal
Reserve System.  FRAS officials agreed with our suggestions for
improvement and, in most cases, initiated corrective actions prior to
the conclusion of our work. 


--------------------
\3 See footnotes 1 and 2. 

\4 General controls are policies and procedures that apply to the
overall effectiveness and security of an entity's computer operations
and create the environment in which other related computer controls
operate.  General controls include the organizational structure,
operating procedures, software security features, and physical
protection designed to ensure that (1) only authorized changes are
made to computer programs, (2) access to computer systems and data is
appropriately restricted, (3) back-up and recovery plans are adequate
to ensure the continuity of essential operations, and (4) computer
security duties are segregated. 


   OPPORTUNITY EXISTS TO IMPROVE
   FEDERAL RESERVE NOTE ACCOUNTING
   AND REPORTING
------------------------------------------------------------ Letter :5

The FRBs used different practices to track new note issuances than
they used to track the notes they held in their vaults, resulting in
inconsistent note accounting and reporting.  Furthermore, various
changes to the Federal Reserve Act, the notes' interchangeable
nature, and the way in which the FRBs meet their note collateral
requirements appear to have made the tracking of note issuances by
identifier unnecessary. 

When new notes are issued, the FRB whose identifying marking appears
on the note records a liability for the note amount.  Notes that are
held in each FRB's vault, regardless of identifier, reduce this
liability to arrive at the reported amount of notes outstanding. 
Consequently, for each FRB, the reported amount of notes outstanding
does not accurately reflect the actual amount of outstanding notes
bearing that FRB's identifier. 

Various changes to the act have also diminished the importance of
these FRB identifiers.  Originally, the act required an identifier on
each note to help ensure that each FRB satisfied statutory gold
reserve requirements for its notes in circulation.  However, these
gold reserve requirements have since been repealed.  Additionally, in
response to changes in the act, notes in the vault are no longer
sorted and recorded by identifier. 

Historically, the identifiers facilitated the FRBs' sorting of notes
to comply with other note-related provisions.  For example, the act
originally prohibited the FRBs from paying out notes with other FRBs'
identifiers to customers.  To comply with the act, each FRB sorted
notes received from customers and returned notes to the other FRBs,
as appropriate.  The Congress eliminated these provisions to reduce
costs and inefficiencies in the FRBs' note-related operations. 

Additionally, under the act's original provisions, the FRBs were
required to return all excessively worn notes to the Comptroller of
the Currency for destruction.  Each FRB was credited with the amount
of its notes to be destroyed.  To further reduce costs, the Congress
amended the act to modify these requirements.  As a result, unfit
notes may be destroyed at any FRB and the Board of Governors then
apportions the note destructions among the FRBs.  The act allows the
Board to determine the method by which note destructions will be
apportioned. 

Other factors affecting notes further diminish the importance of
using identifiers to associate each note with a specific FRB for
accounting and reporting purposes.  As the nation's currency, all
notes are accepted at any FRB and are used interchangeably,
regardless of their identifiers.  In addition, the FRBs comply with
the act's collateral requirements by pledging each FRB's eligible
assets as collateral to secure the notes of all the FRBs.  Individual
FRB note liabilities are less meaningful than the combined note
liability because of the notes' cross-collateralization.  Thus,
continuing to use specific note identifiers to record note
liabilities appears to be unnecessary. 

The FRBs have responded to the inefficiencies involved in using
identifiers to track notes by automating the note accounting and
reporting process.  This has eliminated much of the effort involved
in tracking notes manually.  However, the inconsistency between how
the issuances of new notes and the contents of the vault are
accounted for and reported has continued. 


   FRB FINANCIAL STATEMENTS TO BE
   EXTERNALLY AUDITED
------------------------------------------------------------ Letter :6

In November 1994, the Board contracted with an independent accounting
firm to audit the asset accounts allocated among the FRBs for
calendar years 1994 through 1999.  The contract also requires audits
of the combined financial statements of the FRBs as of December 31
for each of the years from 1995 through 1999.  During these years,
the financial statements of each individual FRB will also be audited
once based on the schedule shown in table 1. 



                                Table 1
                
                 Planned External Independent Audits of
                         Federal Reserve Banks

Year of audit                               Federal Reserve Bank
------------------------------------------  --------------------------
1995                                        Atlanta and St. Louis

1996                                        New York, Richmond, and
                                            Dallas

1997                                        Boston, Philadelphia, and
                                            Minneapolis

1998                                        Chicago and San Francisco

1999                                        Cleveland and Kansas City
----------------------------------------------------------------------
Under this contract, the combined financial statements will be
audited more frequently than the individual statements.  This audit
approach is appropriate in light of the needs of users of the
combined financial statements.  The FRBs operate under agreements
which specify that assets pledged as collateral by each FRB for its
outstanding notes are available to secure the notes of all the FRBs. 
Accordingly, the combined assets of the FRBs are used to determine
whether the notes are adequately collateralized, thus making this
combined presentation the most meaningful. 

These audits of the FRBs' combined financial statements will give the
Federal Reserve the opportunity to make audited financial statements
publicly available.  These annual audits enhance the credibility of
reported information and conforms to the practices of the central
banks of many other major industrialized nations.  Although the
Federal Reserve's past annual reports have included the FRBs'
financial statements, these statements were not audited and lacked
adequate disclosure of key information, such as significant
accounting policies followed by the FRBs.  In contrast, the central
banks of France, Germany, the United Kingdom, and Canada issue
publicly available annual reports that include audited financial
statements and the independent auditors' reports. 

Presently, there is no requirement that the combined financial
statements of the FRBs be audited in accordance with generally
accepted government auditing standards (GAGAS).  Audits conducted
under the contract will be performed in accordance with generally
accepted auditing standards (GAAS).  We believe that performing these
audits under GAGAS would enhance the value of these audits.  GAGAS
audits incorporate the GAAS requirements, but go further by requiring
additional tests of internal controls and compliance with laws and
regulations and reports on these matters. 

The unique role of the FRBs and the nature of records underlying
reported balances of Treasury securities and notes preclude full
reliance on traditional auditing procedures.  For example, confirming
account balances with independent parties is an effective audit
procedure to substantiate reported balances.  However, this procedure
cannot be performed for the FRBs' Treasury security investments and
Federal Reserve note liabilities. 

As part of functions it performs on behalf of Treasury, the New York
FRB maintains the ownership records for Treasury securities,
including those in the FRBs' portfolio.  However, the New York FRB
also maintains the related accounting records for these securities. 
In contrast, Federal Reserve notes are held by parties independent of
the FRBs.  However, records of specific note holders cannot be
maintained because notes continuously circulate throughout the
country and the world.  Consequently, the FRBs' ownership of Treasury
securities and the amount of notes outstanding cannot be
independently confirmed. 

The FRBs retain supporting documentation for the cost of securities
transactions for about 2 years.  As a result, verifying the entire
historical cost of securities that have been in the FRBs' portfolio
for extended periods is difficult.  However, by retaining support and
detailed records for the price paid for new security purchases, the
FRBs could eventually support the entire cost of the securities
portfolio when the current holdings either are sold or mature.  The
portion of recorded cost that cannot be readily supported relates to
security premiums and discounts.  The recorded amounts of premiums
and discounts were not significant to the FRBs' total Treasury
security account balance as of December 31, 1994.  However, auditing
the completeness of these recorded amounts is complicated by the lack
of supporting documentation and records. 

Certain Federal Reserve note characteristics affect related
accounting and further complicate audit efforts.  For example, notes
do not mature or expire.  In some countries, such as the United
Kingdom and France, after a new currency issue is placed in
circulation, the old issue is no longer valid for trade, and the
liability for the old currency is removed after an appropriate
period.  However, the United States does not invalidate old note
issues when a new note issue is placed in circulation.  All notes
issued are recorded as liabilities until returned to the FRBs. 
Additionally, many notes are held by collectors or are held in
foreign countries and may never be returned to the FRBs. 

Destructibility, another note characteristic, also affects the note
balance and complicates the FRB audits.  Since notes were first
issued, they have been destroyed by fires, wars, and other accidents
and natural disasters beyond the FRBs' control.  The value of notes
destroyed in this manner in a single year is unlikely to be large
relative to the balance.  However, the cumulative effect of these
destructions and of other notes that may not be returned to the FRBs
is unknown.  The existence of these factors is not disclosed in the
FRBs' financial statements. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

We commend the Board for taking the step to contract for external,
independent financial statement audits over the next 5 years.  We
believe that the Board's current commitment to auditing the FRBs'
combined financial statements should be sustained and become a
permanent part of the Board's operating practices. 

Presenting audited, combined FRB financial statements that contain
appropriate disclosures will enhance the credibility of the Federal
Reserve's annual report and will help meet the needs of financial
statement users, including the Congress and the public. 
Institutionalizing such annual, external independent audits will also
place the Federal Reserve System on a par with the central banks of
other major industrialized nations with respect to financial
reporting practices.  In conducting these audits, the FRBs' external
auditors will need to address the audit challenges posed by the FRBs'
unique roles. 

Recording note liabilities based on bank identifiers is an
inefficient use of FRB resources, and reporting this liability under
the current approach does not serve a meaningful purpose. 
Discontinuing the practice of tracking and recording each FRB's note
liability based on note identifiers would increase efficiency and
provide a consistent basis for the note liabilities reported by the
FRBs. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :8

To bring about consistency and improve the efficiency of Federal
Reserve note accounting and reporting procedures, we recommend that
in conjunction with planning and implementing future changes to the
automated systems used to account for and report notes, the Board of
Governors of the Federal Reserve System consider

  incorporating changes in the function of these systems to allow
     FRBs to account for and report notes without regard to the
     identifiers printed on the notes;

  directing the FRBs to discontinue using specific FRB identifiers
     printed on notes as the basis for recording each FRB's liability
     for Federal Reserve notes;

  stopping the tracking of shipments by FRB identifiers;

  directing each FRB to record its note liability based on the
     Federal Reserve notes it actually receives and holds without
     regard to FRB identifiers; and

  apportioning note destructions among FRBs on an appropriate basis
     without regard to FRB identifiers. 

To enhance the combined financial statements as a vehicle for
informing Federal Reserve management, the Congress, and the public
about the operations of Federal Reserve Banks, we recommend that the
Board of Governors of the Federal Reserve System do the following: 

  Adopt a policy to institutionalize annual, external independent
     audits of the FRBs' combined financial statements as a routine
     operating procedure.  These audits should be performed in
     accordance with GAGAS. 

  Make the FRBs' audited combined financial statements and
     independent auditor's report publicly available upon issuance. 
     For example, these documents could be included in the Federal
     Reserve System's annual report. 

  Include disclosures in the financial statements that (1)
     appropriately describe the significant accounting policies
     followed, such as the basis for the reported note liability and
     the treatment of the notes held in the vault, and (2) provide
     the information typically included in financial statements of
     other central banks and private sector financial institutions. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

Regarding our recommendations to bring about consistency and improve
the efficiency of Federal Reserve note accounting and reporting
procedures, the Board acknowledged in a letter dated January 11,
1996, that changes to the Federal Reserve Act and Federal Reserve
policies have blurred the distinction among Federal Reserve notes
with different unique identifiers.  The Board acknowledged that the
accounting process for note destructions offers an opportunity for
further efficiencies to be gained in this area.  The Board stated it
will give consideration to the accounting method used for Federal
Reserve notes as the accounting and tracking systems associated with
the notes are reviewed for possible redesign. 

Our other recommendations were intended to enhance the Federal
Reserve Banks' combined financial statements as a vehicle for
informing Federal Reserve management, the Congress, and the public
about the operations of the Federal Reserve Banks, and we believe
implementing them would enhance management's accountability.  The
Board stated it will give careful consideration to our
recommendations concerning the use of external auditors, presentation
of financial statements, and the application of auditing standards. 


---------------------------------------------------------- Letter :9.1

We are sending copies of this report to the Chairman of the Board of
Governors of the Federal Reserve System; the Secretary of the
Treasury; the Chairman of the House Committee on Banking and
Financial Services; the Chairman and Ranking Minority Member of the
Senate Committee on Banking, Housing, and Urban Affairs; and the
Director of the Office of Management and Budget.  Copies will be made
available to others upon request. 

Please contact me at (202) 512-9406 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
II. 

Sincerely yours,

Robert W.  Gramling
Director, Corporate Audits
 and Standards




(See figure in printed edition.)Appendix I
COMMENTS FROM THE BOARD OF
GOVERNORS OF THE FEDERAL RESERVE
SYSTEM
============================================================== Letter 



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Janet M.  Krell, Assistant Director
Charles R.  Fox, Manager

DALLAS REGIONAL OFFICE

Shannon D.  Rapert, Manager
David W.  Irvin, Manager
Norman C.  Poage, Site Senior
Miguel A.  Salas, Site Senior
Shannon Q.  Cross, Evaluator

NEW YORK REGIONAL OFFICE

Francesco DeSantis, Site Senior
Vincent R.  Morello, Site Senior
Allan W.  Gendler, Evaluator
Ralph S.  Meister, Evaluator

OFFICE OF THE GENERAL COUNSEL

Helen T.  Desaulniers, Attorney


*** End of document. ***