FDIC's Capital Investment Management Review Process for Information Technology Investments – Memorandum
September 23, 2004
Audit Report No. 04-039
Federal Deposit Insurance Corporation
Co-Chairmen Capital Investment Review Committee
Washington, D.C. 22226-3500
DATE: September 17, 2004
MEMORANDUM TO: Stephen M. Beard, Deputy Assistant Inspector General for Audits
FROM: Steven O. App [Electronically produced version; original signed by Steven O. App ], Deputy to the Chairman and Chief Financial Officer
Michael E. Bartell [Electronically produced version; original signed by Michael E. Bartell], Chief Information Officer and Director, Division of Information Resources Management
SUBJECT: FDIC's Capital Investment Management Review Process for Information Technology Investments (Report Number 04-039), Management Reconsideration of Recommendation #4
As per your September 30, 2004 transmittal of the subject final audit report, the FDIC has reconsidered the response to recommendation #4. We remain convinced that current procedures provide for adequate independent validation of quarterly project assessments. We also believe that the multi-level review that these quarterly assessments undergo now, the independence that already exists given the make-up of the typical project steering committee, and the final approval authority that is documented and resident with the CIRC is sufficiently documented in our FDIC Capital Investment Policy.
In addition, it is also important to note that as part of our review of this recommendation, management had to take into consideration the fact that DIRM is in the process of a major transformation effort. As a result, there will be substantial organizational changes that will occur in 2005. To be most effective during this time of significant change, DIRM is deferring all non-essential work and is focusing all of its efforts on CIRC projects, steady state projects, and all work deemed "mission critical" by management. Reallocating resources to make additional modifications to an existing policy, that we believe is adequate, is not consistent with our current mission priorities.
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