Executive Summary

Objective and Scope

Background

Results

conclusion

Appendix I - Detailed Objectives, Scope, and Methodology

Appendix II - Major contributors to This Report

Appendix III - Report Distribution List

Appendix IV - Management's Response to the Draft Report

Executive Summary

A previous audit report titled, Examination Division’s Use of Performance Measures and Statistics, dated July 7, 1998, identified concerns that led us to look at whether Examination Division’s emphasis on enforcement results caused taxpayers to be treated improperly. Our review focused on the individual tax returns selected for office audit through means other than the Discriminant Index Function (DIF), primarily through the Midwest Automated compliance System (MAcS).

Given the extent of control breakdowns identified during this audit, we cannot give assurance that IRS employees selected returns for examination fairly or that they protected taxpayers’ personal and financial data from unauthorized and improper disclosure. We also noted inappropriate actions taken by examiners and managers during the initiation and closing of audits that may have led to improper taxpayer treatment. In some instances, examiners may have violated laws or regulations. In other instances, IRS procedures were not followed.

Traditionally, DIF has been the primary workload identification system used to select individual tax returns for office audits. DIF scores each return for potential errors by means of a mathematical formula. The higher the score, the greater the probability for error. When the computer selects a return because of a high DIF score, an employee, generally in one of IRS’ Service centers, screens the return for some obvious explanation or innocent error. If none is found, the questionable return is usually forwarded to the district for audit consideration. This process provides IRS with controls to (1) identify and select returns for audit and (2) separate the duties among employees identifying, selecting and auditing tax returns.

comparatively, MAcS gives IRS employees a new and innovative way of identifying and selecting returns for audit. MAcS provides IRS employees in district offices the ability to use locally-derived, and possibly subjective, criteria to both identify and select returns for audit from the millions of returns filed within the district’s geographical boundaries.

IRS reports that MAcS, unlike most other IRS computer systems, has controlled access protection to prevent and detect unauthorized access and misuse of taxpayer data. Officials in IRS’ National Office developed comprehensive guidelines that outline additional procedures and controls to aid in protecting the security and privacy of taxpayer information on MAcS. However, our tests and on-site visits to 14 district office MAcS sites found a combination of factors that seriously undermined the entire MAcS control environment. For instance:

• Over a two-month period, IRS employees in 14 districts accessed over 3,600 accounts on MAcS that could not be traced to source documents that adequately explained the business purpose for the accesses. Vague MAcS research requests, such as "identify taxpayers in specific market segments that will produce productive examinations," were used as control documents to support hundreds of account accesses (5 of 14 districts). Public Law, Treasury Directives, and the Internal Revenue Manual (IRM) prohibit IRS employees from obtaining access to taxpayer accounts without a valid business purpose. We are coordinating with our Unauthorized Access (UNAX) Program to further investigate these potential violations.
• Inadequate separation of duties existed among IRS employees responsible for identifying, selecting, and auditing tax returns (7 of 14 districts).
• MAcS data discs containing return information were not adequately secured (4 of 14 districts).
• controls were not established over MAcS returns while they were screened for audit potential (12 of 14 districts).
• Audit trail files designed to detect an unauthorized access once it occurs were not reviewed, backed-up or maintained (13 of 14 districts).

Although IRS has established procedures to protect taxpayers during audits, we found examples of what we consider to be improper taxpayer treatment during the initiation and closing of office audits. For example:

• We found no evidence in 803 of 1,806 sample cases reviewed that IRS employees provided taxpayers with a Publication 1 (Your Rights as a Taxpayer) and/or Notice 609 (Privacy Act Notice) at the initiation of the audit, both of which are statutory requirements.
• IRS employees used discretionary enforcement powers in a way that appeared to create an unnecessary hardship for taxpayers. In 2 districts, 3,500 audits of low- income taxpayers claiming an Earned Income Tax credit were started by sending a 6-page questionnaire requesting more than 80 items of information. The items requested included amounts spent on food, clothing, gifts, and cosmetics. Much of the information requested was intrusive and had little, if any, relevance to the issues being questioned.
• IRS employees in 15 districts improperly closed 211 returns as "surveys" (non-examined disposals) instead of closing them as being "examined without a change" or "with an additional assessment." This practice reduced the reliability of program statistics and could lead to inadvertently violating the prohibition against repetitive audits under Internal Revenue code §7605 if the same tax period were subsequently examined.

The risk of selectively targeting taxpayers for examination and exposing the personal and financial data of millions of taxpayers to browsing and improper disclosure could be easier managed by centralizing the MAcS sites. A better separation of duties could be achieved between the IRS employees responsible for identifying potential MAcS returns for audit and the employees responsible for conducting the examination by locating MAcS in offices other than those that will be working the audits.

IRS management also needs to strengthen specific IRS controls and procedures for initiating and closing audits. These include (1) making sure examiners and managers are knowledgeable of procedures designed to protect taxpayers during audits and (2) expanding the quality assurance controls to address taxpayer rights.

Due to the significant risks inherent in the selection, initiation, and closing of examinations, and the current state of the controls designed to mitigate those risks, these areas should be declared material weaknesses under the Federal Manager’s Financial Integrity Act (FMFIA).

Management's Response: The commissioner of the Internal Revenue Service provided comments on a draft of this report in a February 12, 1999, letter.

Objective and Scope

Our primary objective was to assess the effectiveness of controls that protect taxpayers’ rights during office audits. We attempted to identify instances where taxpayers were, or could perceive that they were, harmed when an Internal Revenue Service (IRS) employee (1) violated a law or regulation, or (2) did not follow IRS procedures governing interactions with taxpayers. A brief description of the tests we performed included:

• Evaluating controls over access to taxpayer information on the Midwest Automated compliance System (MAcS) to determine if taxpayer data were safeguarded against improper access or misuse during the audit identification and selection processes.
• Reviewing samples of closed and open cases to determine if taxpayers were treated properly during the initiation and closing of non-Discriminant Index Function (DIF) audits. In instances where it appeared actions were inappropriate, we evaluated the impact of those actions on program statistics.

We conducted fieldwork in 27 of the 33 IRS district offices from April 1998 through August 1998. Our review was conducted in accordance with generally accepted government auditing standards.

Appendix I contains the detailed objectives, scope, and methodology of our review. A listing of major contributors to this report is shown in Appendix II.

Background

Traditionally, the DIF has been the primary workload identification system that IRS uses to select individual returns for audit. The DIF system rates each return filed for potential errors by means of a mathematical formula.

Results

Given the extent of control breakdowns identified during this audit, we cannot give assurance that IRS employees selected returns for examination fairly, or that they protected taxpayers’ personal and financial data from unauthorized and improper disclosure. We also noted inappropriate actions taken by examiners and managers during the initiation and closing of audits that may have led to improper taxpayer treatment. In some instances, examiners may have violated laws or regulations. In other instances, IRS procedures were not followed.

Weaknesses in the MAcS control Environment Unnecessarily Exposed Taxpayer Return Data to Browsing and Increased the Risk That Employees could Selectively Target Individuals for Audit

IRS reports that MAcS has controlled access protection to prevent and detect unauthorized accesses and misuse of taxpayer data. Officials in IRS’ National Office developed comprehensive guidelines that outline additional procedures and controls to aid in protecting the security and privacy of taxpayer information located in the 44 MAcS sites across the nation. However, weaknesses in how those procedures and controls were implemented seriously undermined the MAcS control environment.

We were unable to determine if taxpayers had been selectively targeted for audit, due to weak controls in the MAcS environment. However, we are coordinating with officials in our Unauthorized Access (UNAX) Program to identify instances of browsing as outlined in 18 USc §1030. In all, we visited 14 district office MAcS sites and found the following control breakdowns:

Unexplained accesses to taxpayer accounts (14 of 14 districts). Unless there is sufficient information to justify accesses to taxpayer accounts, IRS is vulnerable to allegations that it targeted taxpayers for audit and that employees browsed taxpayers’ accounts. We were not able to trace over 3,600 accesses made to taxpayer accounts over a two-month period to a MAcS research request, Audit Information Management System (AIMS) listing, or other specific documentation such as MAcS queries/filter lists.

control documents severely limited the capability to prevent and detect unauthorized accesses (5 of 14 districts). Unless control documents are prepared uniformly and contain sufficient information to justify accesses to taxpayer accounts, it is nearly impossible to assure stakeholders that there has not been browsing, disclosure, or that an individual has not been selectively targeted for audit. We found instances where vague requests such as "identify taxpayers in specific market segments that will produce productive examinations" were used as control documents to support hundreds of account accesses.

Inadequate separation of duties existed between examiners who identified returns with potential tax changes for their group and examiners who conducted the audit (7 of 14 districts). Unless there is a separation of duties in these areas – a key control in the DIF system – an IRS employee could more easily selectively target individuals for audit. A recent investigation found that an employee assigned to a compliance project obtained the tax returns of, and initiated an examination against, a neighbor with whom the auditor was having a personal dispute.

MAcS data discs (cDs) could not be readily accounted for and were not always adequately secured (4 of 14 districts). Unless all discs containing electronic MAcS data are accounted for properly, millions of taxpayers’ personal and financial data could be subject to improper disclosure, unauthorized access, and misuse. IRS procedures indicate that cDs should be stored in an off-site location, preferably in a vault. In one office, a former system administrator had two cDs containing taxpayer data. In another office, MAcS cDs and software were stored in an unlocked cabinet within the Automated Examination Systems work area. The cabinet was accessible to all employees working in or visiting the area.

controls were not established over MAcS facsimile returns while they were screened for audit potential (12 of 14 districts). Unless MAcS facsimile returns can be identified and located throughout the audit selection process, there is an increased risk that sensitive data could be lost, stolen, or improperly disclosed. For example, MAcS facsimile returns are routinely printed, screened by examiners, and either shredded or selected for audit before they are entered onto IRS’ control systems, Examination Returns control System (ERcS)/AIMS. This practice is contrary to the DIF system where returns are controlled on AIMS during the classification and selection processes.

Audit trail files were not always reviewed, backed up, and/or maintained (13 of 14 districts). Unless audit trails are retained and reviewed, allegations of unauthorized accesses cannot be investigated nor can patterns of use be evaluated to identify other integrity problems. Through discussions with staff at several sites, we determined they had not performed the required reviews. In addition, they indicated they had not received adequate training to identify inappropriate accesses and potential misuse of MAcS data. In two districts, poor maintenance contributed to the irrevocable loss of audit trail data.

command level audit trails were not capturing system level activity because they were disabled or not working (7 of 14 districts). Unless command level audit trails are functioning properly, security officer and system administrator actions are not recorded. As a result, taxpayer records could be copied without authorization or critical files such as audit trails that capture accesses to taxpayer records could be deleted without detection.

MAcS audit trail files did not automatically capture system queries (14 of 14 districts). Unless audit trail files systematically record the formulas (MAcS filters) used to query MAcS returns, it is very difficult, if not impossible, to provide assurance to stakeholders that there has not been browsing, disclosure, or other integrity problems. For example, one district’s audit trail files for a two-month period show taxpayer return data were accessed through 679 queries. However, the components or formulas could be identified and evaluated only through "saved" files in 54 of the 679 queries.

Passwords to MAcS were shared among multiple users (1 of 14 districts). When a password is shared, a critical component of computer security is missing because it is the basis of controlling access to taxpayer data and for establishing user accountability.

We believe these control breakdowns occurred because the responsibility for maintaining controls over large amounts of sensitive data was decentralized to many employees at many sites. Because these problems could seriously erode the public’s confidence in IRS’ ability to protect the privacy and security of taxpayer personal and financial information, IRS management should take the following actions:

Recommendation #1: Declare MAcS a significant control weakness under the Federal Manager’s Financial Integrity Act (FMFIA).

Recommendation #2: centralize the 44 MAcS sites. The risk of exposing millions of taxpayer returns to browsing, disclosure, or other integrity problems will be easier to manage with fewer MAcS sites and with fewer employees having access to the system.

Recommendation #3: Require a separation of duties among auditors who identify MAcS returns with potential tax changes, auditors who select MAcS returns to be audited, and auditors who conduct the examinations. This could be accomplished by locating MAcS in offices other than those that will be performing the audits.

Recommendation #4: Ensure that all MAcS data discs forwarded from the MAcS Development center (MDc) to district offices are properly accounted for and secured. IRS officials stated that MAcS program files are needed to access the data. However, with today’s technology and skill level of computer users, additional security controls are needed. We suggest encrypting the data and making the data inaccessible at a pre-determined time.

Recommendation #5: Ensure ERcS/AIMS controls are established over all printed MAcS facsimiles so that the location and status of returns can be identified. controls over MAcS examinations would then be similar to those identified by DIF.

Recommendation #6: Ensure appropriate employees, including managers, are knowledgeable of MAcS audit trail files and how the information can be used to detect an unauthorized access once it occurs.

Recommendation #7: Use a proven device to automatically record system level activity.

Recommendation #8: change audit trail files so that they systemically record query components (MAcS filters).

Recommendation #9: Ban the use of vague MAcS research requests and provide examples of properly prepared research requests in the Internal Revenue Manual (IRM) MAcS handbook for the staff to follow. At a minimum, each request should be for a specific taxpayer, select group of taxpayers, or specific project.

Management’s Response: The commissioner agreed with our recommendation to report MAcS as a material weakness under FMFIA. The control weaknesses surrounding MAcS will be included with other management control breakdowns applicable to the selection, classification, assignment, and control of returns.

Office of Audit’s comment: Our discussions with IRS officials indicate they are considering centralizing management oversight of MAcS under a National Office analyst as a short-term solution. IRS officials envision the analyst would be responsible for reviewing and approving MAcS research requests.

Actions Taken by Examiners and Managers During the Initiation and closing of Non-DIF Audits Led to Improper Taxpayer Treatment

We reviewed 1,806 Fiscal Year 1997 non-DIF closed examinations and 577 non-examined disposals from 80 office audit groups (a total of 2,383 returns from 27 districts). We also supplemented our closed case reviews with on-site visits to 27 groups in 14 district offices. From the information in the case files and on-site visits, we identified the following areas in the initiation and closing of audits where actions taken by examiners and managers may have led to improper taxpayer treatment and/or reduced reliability of program statistics.

Audit initiation letters for 3,500 audits in 2 districts contained unreasonable and intrusive requests for information. Requests for information from low-income taxpayers claiming an Earned Income Tax credit (EITc) contained over 80 items for the taxpayer to consider. In addition, information requested such as amounts spent on food, clothing, gifts, cosmetics, and laundry had little, if any, relevance to the issues being questioned.

Taxpayers were not always properly notified that an examination had been initiated (1,117 out of 1,806 audits from 27 districts). These cases showed no evidence that taxpayers were forwarded one or more notifications required by law or procedures, such as Publication 1 (Your Rights as a Taxpayer), Notice 609 (Privacy Act Notice), and Notice 782 (Information on Tax Examinations). Internal Revenue code §7521 indicates that IRS should provide Publication 1 to taxpayers when they are audited. The Privacy Act of 1974 also requires that IRS provide the Notice 609 to taxpayers that are selected for audit. Figure 2 shows the number of cases where we found no evidence that taxpayers were forwarded required notifications at the start of their audits.

Figure 2

Form letters were altered without permission from IRS’ National Office. These letters contained conflicting or confusing information that could add to perceptions that the IRS treated taxpayers inconsistently (573 out of 1,806 audits from 26 districts). Instead of using the standard audit initiation letters to begin these audits, IRS field office employees initiated them with either a Notice of Proposed Adjustments (30-day letter), collection Division Letter 964(DO), or other locally generated letter. For example, taxpayers in 1 district were only given 5 days to agree with proposed changes or request a meeting with the IRS Appeals Function before 90-day letters were issued to them. IRS procedures and publications indicate that taxpayers should have, at a minimum, 30 days to consider proposed changes.

case files showed no evidence that examiners considered using corporate Files On-line (cFOL) before requesting taxpayers to provide copies of their tax returns (343 out of 1,410 applicable audits from 21 districts). Taxpayers were routinely requested to provide IRS with copies of their returns so examiners could determine whether the audit needed to be expanded. The issue(s) raised in many cases could have been resolved using IRS facsimile returns. Requesting taxpayers to provide IRS with returns previously submitted unnecessarily imposes additional burden.

AIMS procedures were not properly followed, which reduced the reliability of cycle time, a key program statistic for tracking the length of examinations (361 out of 1,806 audits from 26 districts). This condition involved groups not consistently updating returns to the correct AIMS status code to show that an audit had been initiated. Because AIMS updating procedures were not followed, cycle time for 361 audits was understated by an estimated 53,177 days (147 average days per audit).

Returns selected for audit were improperly closed as "surveys" (non-examined closures) instead of as "examined without a change" or "with an additional assessment" (211 out of 785 non-examined returns from 15 districts). This practice reduces the reliability of program statistics, causes taxpayers to be treated inconsistently, and could lead to inadvertently violating the prohibition against repetitive audits under Internal Revenue code §7605 if the same tax period is subsequently examined. In one case, a taxpayer agreed to, and paid a partial payment toward, a deficiency even though the return was stamped and signed by the group manager as a "survey."

Our evaluation of these concerns suggests two overriding factors contributed to the problems. Additional steps must be taken at the group level and quality control level to ensure taxpayers with returns in the audit stream are treated properly.

IRS has many procedures in place to help govern its interactions with taxpayers that should help make sure taxpayers are treated properly. Among the procedures are:

• Providing Publication 1 (Your Rights as a Taxpayer), Notice 609 (Privacy Act Notice), and Notice 782, (Information on Tax Examinations) when notifying taxpayers that their return will be examined.
• Requiring that public-use forms such as audit initiation letters and Notices of Proposed changes (30-day letters) not be altered without National Office approval.
• Requiring examiners to use the cFOL system instead of taxpayer copies for information relating to prior and subsequent year returns.
• Limiting unreasonable and intrusive requests for personal expense items associated with financial status audits and economic reality examination techniques.

Many of the cases where laws and/or procedures were not followed involved returns with one or two issues that were handled as correspondence audits. Lower-grade examiners who may have relatively little office audit experience typically work these cases. For example, management in one district showed us a group made up exclusively of employees, including the group manager, who had recently transferred from other IRS positions and had no prior office audit experience.

IRS’ office audit guidelines provide very little direction for examiners conducting correspondence audits in district offices. The IRM contains only two paragraphs indicating that correspondence audits should be examined by service center personnel and only in limited circumstances by district office examiners.

The use of relatively inexperienced examiners, when combined with a lack of IRM guidance and the other concerns raised in our case reviews, strongly suggest that IRS management needs to take the following actions.

Recommendation #10: Declare the control system designed to protect taxpayers during the initiating and closing of office audits as a material weakness under FMFIA.

Recommendation #11: Take appropriate remedial action in all office audit cases opened, closed, and surveyed within the last 12 months where taxpayers were not properly informed of their rights or where audits were improperly closed as surveys.

Recommendation #12: Ensure examiners, including managers, are better informed and educated about IRS procedures that are designed to ensure taxpayers are treated properly during audits. These actions could include (1) issuing a memorandum to employees and group managers emphasizing existing IRS procedures for safeguarding taxpayer rights and (2) communicating procedures in future continuing Professional Education sessions and/or training class modules.

Recommendation #13: clarify the IRM to provide specific guidance for conducting correspondence audits in district office settings.

Management's Response: The commissioner agreed that control breakdowns occurred and will be reporting them as material control weaknesses under the FMFIA. In addition, he stated that IRS would:

• Prepare a comprehensive memorandum to the field offices that provides procedures and requirements for conducting correspondence examinations in the district environment.
• Provide training for managers, examiners, and PSP personnel reinforcing their responsibilities for ensuring that all taxpayer rights are protected. Appropriate procedures for correspondence examinations will be emphasized as part of this training.
• Include comprehensive requirements for protecting taxpayer rights and for documenting the actions taken in the new IRM Handbook "Examination of Returns."
• Emphasize protection of taxpayer rights and the use of appropriate correspondence procedures in all future peer reviews.
• Develop an action plan for taking remedial action in cases where taxpayers were not treated properly.

Among other responsibilities, the Quality Measurement Staff, under the Office of compliance Specialization, evaluates samples of closed examinations to identify technical and procedural problems, and to advise management when corrective actions are needed. The Examination Quality Measurement Systems (EQMS) sets forth nine standards, and additional key elements within each standard, that are used by the Quality Measurement Staff to make their closed case evaluations.

The standards and their key elements provide guidance to auditors and measures for management on how well (1) time is managed, (2) large and unusual items are checked, (3) probes for unreported income are performed, and (4) workpapers are prepared. The nine standards and their elements provide very little, if any, guidance to auditors or feedback to managers on how well IRS’ procedures governing taxpayer treatment are followed during audits.

To gauge taxpayer perceptions about the audit process, EQMS sends a questionnaire to taxpayers who were recently examined. However, IRS officials told us that only about 50 percent of the taxpayers responded, which potentially reduces the reliability of the results. While the questionnaire has value, IRS would get a more complete picture of how taxpayers were treated during audits by evaluating the issue through EQMS reviews.

Another concern related to quality controls is that IRS does not have a system in place to evaluate the appropriateness of or trends in non-examined disposals. To ensure non-examined disposals, such as"surveys," are proper, IRS relies on the group manager. However, we question the effectiveness of this control after finding instances where managers approved non-examined closures after taxpayers were contacted and records obtained.

A system such as EQMS needs to be used to determine whether non-examined disposals are appropriate. Besides determining if the disposal was proper, the system could also be used to identify trends for improving return ordering and selection.

Recommendation #14: Expand EQMS standards and/or key elements to address the proper treatment of taxpayers, including whether managers were involved in unagreed cases.

Recommendation #15: Implement a system to determine whether non-examined disposals ("surveys") are appropriate and to aid in identifying trends for improving return ordering and selection.

Management's Response: The commissioner agreed with our recommendation of having EQMS reviews evaluate how taxpayers are treated during audits and whether managers are involved in resolving disagreements. He included the revised EQMS standards as an attachment to his response.

conclusion

Due to the control breakdowns and the inappropriate practices identified during this audit, the IRS risks:

1. Losing the public’s confidence in its ability to protect the privacy and security of taxpayers’ personal and financial information.
2. contributing to taxpayers’ perceptions that they are not treated fairly by the IRS.

By implementing the recommendations presented in this report, IRS management can reduce taxpayer burden and significantly reduce the risks that taxpayer rights will be abused.

Detailed Objectives, Scope, and Methodology

We attempted to identify, through closed case reviews and on-site visits, instances where taxpayers were, or could perceive they were, harmed when an Internal Revenue Service (IRS) employee (1) violated a law or regulation, or (2) did not follow IRS procedures that govern its interactions with taxpayers. Initially we selected, for our closed case review and on-site visits, the 20 tax auditor groups in each region (80 groups in 27 districts) that generated the most dollars per hour in Fiscal Year (FY) 1997.

For our closed case review, we judgmentally sampled from each group 40 closures that included agreed assessments, non-examined disposals, and assessments that defaulted. Although we reviewed cases from 27 of 33 district offices, the actual number of cases reviewed varied from group to group because some cases could not be obtained within our scheduled time frame for completion and because of the groups’ case closure patterns. We decided not to pursue on-site testing in 13 of 27 districts initially selected after assessing the extent of control breakdowns in the first 14 districts visited. Test results from the 14 districts clearly indicate that taxpayer treatment is a concern nationwide. Table 1 on the following page details the districts included in the review. Overall, we:

• Evaluated a sample of 702 agreed examinations closed by 27 district offices in FY 1997.
• Evaluated a sample of 490 no-show/no-response examinations closed by 25 district offices in FY 1997.
• Evaluated a sample of 624 defaulted examinations closed by 25 district offices in FY 1997.
• Evaluated a sample of 785 returns closed as non-examined disposals by 24 district offices in FY 1997.
• Performed on-site visits to 27 office audit groups in 14 district offices to assess current office audit practices.
• Performed on-site visits to 14 district offices and evaluated how well controls protected access to tax return information on the Midwest Automated compliance System.

Major contributors to This Report

Stephen R. Mullins, Regional Inspector General for Audit

Frank J. Dunleavy, control Audit Manager

Randee cook, Support Audit Manager

Richard T. Hayes, Support Audit Manager

Ronald F. Koperniak, Support Audit Manager

Earl charles Burney, Lead Auditor

William Denson, Lead Auditor

Stanley M. Pinkston, Auditor

Allen L. Brooks, Auditor

Sharon A. Buford, Auditor

Richard J. Flynn, Auditor

Robert N. Nguyen, Auditor

Joan Raniolo, Auditor

Report Distribution List

Deputy commissioner for Operations c:DO

chief Operations Officer OP

Assistant commissioner (Examination) OP:EX

National Director for Legislative Affairs cL:LA

Office of Management controls M:cFO:A:M

Audit Liaisons

chief Operations Officer OP

Assistant commissioner (Examination) OP:EX

Regional commissioner (Mid-States)

Regional commissioner (Northeast)

Regional commissioner (Southeast)

Regional commissioner (Western)

District Director (Illinois)

District Director (Arkansas-Oklahoma)

District Director (North Texas)

District Director (Houston)

District Director (New England)

District Director (Manhattan)

District Director (New Jersey)

District Director (Virginia-West Virginia)

District Director (North-South carolina)

District Director (Gulf coast)

District Director (Southern california)

District Director (Rocky Mountain)

District Director (Southwest)

District Director (Northern california)

District Director (Los Angeles)

Management’s Response to the Draft Report

Response has been removed due to its size. To see the complete Response, please go to the Adobe PDF version of this report.