Bulletin No. 2024-07 | TFX: Treasury Financial Experience

Expiration Date: November 30, 2024

To: Heads of Government Departments, Entities, and Others Concerned

Subject: Appendix 4 – CFO Representation Form Update

1. Purpose

This bulletin provides entities with the updated questions related to TFM Volume I, Part 2, Chapter 4700 - Appendix 4 CFO Representation Form. In addition, this bulletin provides clarification on the revised/new questions on the CFO Form.

2. Authority

Department of the Treasury (Treasury) requires all federal entities to provide Fiscal Service with the required fiscal year-end data that is used to prepare the Financial Report. All federal entities (significant or other) must submit GTAS ATB data and manual adjustments that crosswalk to the federal entity’s audited financial statements, as the GTAS Balance Sheet and the reclassified financial statements provide the connection to the data in the Financial Report. Refer to: TFM Volume 1, Part 2, Chapter 4700, Section 4710 Scope and Applicability

3. Background

As a result of multiple ongoing initiatives established over the past few years, Treasury and Office of Management and Budget (OMB) have seen a significant decrease in intra-governmental elimination differences submitted by entities. Treasury and OMB continue to monitor the raw intra-governmental data from the entities to verify the data continues to reflect a decrease in intra-governmental elimination differences submitted by entities. Based on the fiscal year (FY) 2020 IGT differences, Government Accountability Office (GAO) recognized this progress by changing the narrative in the Independent Audit Report from “material” amounts to “significant” amounts in describing the remaining IGT differences. While Treasury analyzed the results of a survey from entities to learn more about their internal controls and processes related to IGT reporting, GAO did not close this audit recommendation as additional assurance that entities are establishing necessary IGT controls and auditors subsequent testing on those controls are required. Another way Treasury is working to prove entities internal controls is additional questions and data requested in Appendix 4 – CFO Representation Form. In order to support entity establishment of controls, centralized guidance to serve as the baseline requirements may be necessary in OMB Circular No. A-136, OMB Audit Bulletin, GAO’s Financial Audit Manual (FAM), and the Treasury Financial Manual TFM Volume I, Part 2, Chapter 4700.

4. Appendix 4 - CFO Representation Form Timeline

Fiscal Service has readdressed questions M - Q in Appendix 4 in an effort for entities to provide more information regarding entities internal controls.

November 29th, 2024 - CFO Representation Form due to Fiscal Service

5. Appendix 4 – CFO Representation Form Update

M. Does the federal entity have internal controls which include: identifying and properly recording intra-governmental transactions, reconciling, and resolving intra-governmental differences with the trading partner, and correctly reporting intra-governmental activity and balances by trading partner to the Department of the Treasury through the Government-wide Treasury Account Symbol Adjusted Trial Balance System (GTAS)?

If not, please explain why.

N. Are the federal entities internal controls in the previous question, covered by an A-123 audit or other audit review process?

If not, please explain why.

O. Does the federal entity collaborate and engage with trading partners to resolve intra-governmental differences that go beyond Fiscal Services processes? For example, do you collaborate with your trading partners to identify and reconcile transactions below the MDR and TDF thresholds for intra-governmental differences? This would not include collaboration done as a result of a Material Difference Report (MDR), Targeted Difference Form (TDF), or Root Causes Analysis/Corrective Action Plan (CAP). Responses should include federal entity-initiated processes.

If so, please describe.

P. Does the federal entity’s A-123 or other review include the assessment of intra-departmental activity? If intra-departmental differences exist, explain why they were not resolved by year-end.

Q. Does the federal entity perform internal controls over intra-governmental transactions and balances that includes properly identifying, recording and reconciling balances prior to reporting in GTAS?

If not, please explain why.

6. References

For additional details, please refer to Fiscal Service’s TFM Volume I, Part 2, Chapter 4700 CFO Representation Form website.

7. Effective Date

This bulletin is effective immediately.

8. Inquiries

Direct questions concerning this bulletin to:

Intragovernmental Transaction and Reconciliation Branch

Bureau of the Fiscal Service

Email: GovernmentwideIGT@fiscal.treasury.gov