MAC CONTINUOUS AUDIT REPORT st QUARTER

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1 Page 1 of 16 MEMORANDUM TO: Finance and Administration Committee FROM: Scott Zaczkowski, Director-Internal Audit ( ) SUBJECT: MAC CONTINUOUS AUDIT REPORT st QUARTER DATE: July 17, 2017 A continuous audit process has been implemented by the MAC Internal Audit Department in accordance with the MAC 2017 Internal Audit Plan. The attached report contains an overview of the current continuous audit process including audit objectives, audit scope, associated audit testing, and a summary of results for the first quarter of COMMITTEE ACTION REQUESTED: RECOMMEND TO THE FULL COMMISSION ACCEPTANCE OF THE MAC INTERNAL AUDIT DEPARTMENT CONTINUOUS AUDIT REPORT ST QUARTER RESULTS.

2 Page 2 of 16 July 14, 2017 Mr. Brian Ryks, Executive Director and Chief Executive Officer Metropolitan Airports Commission Dear Mr. Ryks, A continuous audit of Metropolitan Airports Commission financial controls and compliance for the first quarter of 2017 has been completed and was conducted in accordance with the Standards for the Professional Practice of Internal Auditing. The following is a discussion of the objectives and scope of work performed, background information and summary of results. CONTINUOUS AUDIT OBJECTIVES The purpose of our audit procedures was to review and analyze MAC business and accounting functions and results across a broad spectrum for a limited recent timeframe using computerized data analysis techniques combined with audit testing follow-up. Our audit procedures are risk based and are designed to identify and test the design and effectiveness of key internal controls related to MAC business functions as well as compliance with applicable legal and policy provisions. In developing our audit scope and testing plans we considered inherent financial risks including fraud risks in each business area, related controls, and the residual risks that remained after the application of controls. Our audit testing process is completed each quarter with a summary report of results going to the Commission and Senior Management. AUDIT SCOPE Our audit procedures focused on the testing of key controls and compliance related to MAC financial activities. The audit testing listed in the attached Continuous Audit Testing Matrix was developed by MAC auditors to address the risks that, in our opinion, require continuous audit testing and review. Risk areas, testing objectives, and related testing procedures are reassessed for each audit cycle (quarter year) and adjusted as needed. The testing period addressed in this report was for the first quarter of 2017 (months of January, February and March). The timing of our audit procedures is designed to keep audit testing as current as possible while allowing enough time after the end of each audit cycle to perform adequate testing and follow-up on potential audit issues.

3 Page 3 of 16 DETERMINATION OF CONTINUOUS AUDIT SCOPE Areas assigned for continuous audit testing are in accordance with our Commission approved 2017 Annual Audit Plan and are determined based on the following factors: Risk of Material misstatement or loss of MAC assets Estimated effectiveness of financial controls in place Estimated risk of error, fraud or misappropriation Total dollar amount The tables below provide a breakdown of the scope of our continuous review of financial transactions related to MAC operating revenues and expenses for the first quarter of 2017 along with a brief risk ranking for each area and a breakdown of how each category is covered in our continuous audit process. The dollar amounts shown reflect the total dollar value of transactions tested in each area and are not for financial reporting purposes. In addition to operating revenues and expenses shown below, our audit procedures also include a regular review of payments associated with capitalized costs such as capital equipment payments and capital project payments including capitalized professional services payments. 2

4 Page 4 of 16 BUSINESS AREA ST QTR AUDIT POPULATION TOTAL DOLLARS ($=000) ESTIMATED RISK OF MATERIAL MISSTATEMENT OR LOSS CONTINUOUS AUDIT CATEGORY Airline Rates and Charges $26,293 LOW: Airline Rates and Charges are based on a cost recovery system. MAC recovers the actual cost of airside operations through rates and charges with a year end reconciliation. Accounts Receivable OPERATING REVENUE SOURCES Concessions (Food and Beverage, News, Retail, Passenger Services, Other Concessions) Parking- Ground Transportation (Employee Parking, Access Fees, Taxis, Transportation Network Companies) Auto Rental (Percent Rent and Customer Facilities Charges) Building and Ground Rents (MSP and Relievers) $8,589 $30,462 $7,724 $6,517 MEDIUM : Rent paid to MAC is based on a percentage of recorded gross sales. Audit procedures are needed to verify that gross sales and related rent payments are correctly reported and paid. MEDIUM : Collection of parking revenue is conducted by an outside management company. Transportation Network Companies (TNC's - Uber, Lyft) are new to the airport in 2017 and will require significant audit procedures. MEDIUM : Rent paid to MAC is based on a percentage of recorded gross sales. Audit procedures are needed to verify that gross sales and related rent payments are correctly reported and paid. LOW: Building and Ground Rents are based on MAC approved rental rates and MAC calculated rent billings. Rentals are billed to tenants on MAC's Accounts Receivable System. Past due accounts are tracked and reported to the Commission. Food and Beverage/ Retail/Vending/Services Parking/Ground Transportation Auto Rental Accounts Receivable Utilities/Other $1,849 LOW: Utilities are based on MAC approved utility and service rates and MAC calculated billings. Utilities and other costs are billed to tenants on MAC's Accounts Receivable System. Past due accounts are tracked and reported to the Commission. Accounts Receivable 3

5 Page 5 of 16 BUSINESS AREA ST QTR AUDIT POPULATION TOTAL DOLLARS ($=000) ESTIMATED RISK OF MATERIAL MISSTATEMENT OR LOSS CONTINUOUS AUDIT CATEGORY Personnel $18,272 MEDIUM: Payroll disbursements are based on hours reported by employees and approved by supervisors. Payroll Administration is complex and prone to errors or intentional misstatement. Benefits Administration process is complex and prone to errors. Payroll/Employee Benefits Administrative Expense $600 MEDIUM : Payments to vendors are typically made with purchasing cards. The flexibility in the process elevates the risk of misuse of MAC funds. Purchasing Card / Accounts Payable OPERATING EXPENSES Professional Services $694 Utilities $3,377 Operating Services $2,789 MEDIUM : Professional Service contracts are administered primarily by the departments who hire the service providers. Due to the intangible nature of professional services, the risk of inappropriate payments authorized by department managers is elevated. LOW : Utility payments are based on invoices received from utility providers. The risk of errors or fraud is low. LOW : Operating Services costs are based on service contracts with established rate schedules and vendor invoices for various services. Payments are out of budgeted funds and budget variances are tracked and reported to the Commission. Accounts Payable Accounts Payable Accounts Payable / Purchasing Card Maintenance $9,700 LOW : Maintenance costs are based on contracts with established rate schedules and vendor invoices for various supplies and services. Payments are out of budgeted funds and budget variances are tracked and reported to the Commission. Accounts Payable / Purchasing Card Other $1,339 LOW : Items purchased include primarily insurance, minor assets and supplies. Accounts Payable / Purchasing Card CONTINUOUS AUDIT METHODOLOGY Using the continuous audit approach, MAC auditors identify errors and anomalies shortly after they occur for discussion with appropriate staff or business partners to develop corrective actions or to enhance existing procedures and controls. Errors and control issues are normally identified and corrected at an early stage while they are still small and easily manageable. The possible existence of fraud is considered in developing all audit analysis and testing procedures. Problem areas that are identified in each audit cycle receive immediate follow-up in the following audit cycle and beyond. If problems become significant or recur in successive audit cycles, further audit testing and reporting is then conducted. The following matrix provides a breakdown of the principal audit testing areas that are currently included in our continuous audit process. 4

6 Page 6 of 16 CONTINUOUS AUDIT TESTING MATRIX Recalculate parking fees by first recalculating the elapsed time for each transaction and then applying the proper hourly or daily Parking fees were properly calculated rate to the elapsed time. and the correct rates were used. Compare recalculated fees to However, immaterial errors were actual fees charged. discovered, see note below. Review promotional rate changes to ensure the rate changes were accurately applied and turned off appropriately. No errors were found. RECEIPTS PARKING REVENUE Perform an observation of the reduction procedures used by the cashiers and control room to ensure that the control room approves reductions before the cashier can proceed. No significant issues were identified. Perform an analytical review of reductions by reduction type and compare from month to month. Test a sample of parking validations for proper logging by the issuing area and documentation of the purpose of each validation. Based on the trend analysis performed, reductions appeared to be normal. No issues were noted. Periodic Reconcile all reduction types in the rebates table to the sales reports in the Revenue Control System (RCS). Immaterial errors noted include: 1) some duplicate transactions and 2) disputed fee rebates do not appear in RCS. Perform an analytical review of exception transactions by type and cashier and compare activity from month to month. Review a sample of parking exceptions and reductions for proper documentation, approval, accuracy and valid business purpose. Based on the trend analysis performed, no significant increases in exception transactions were identified. A sample of exceptions and rebates were reviewed for proper documentation, approval, accuracy and valid business purpose. Some immaterial errors were discovered, see below. Our testing found 120 transactions totaling $1,819 w here the rates w ere not accurately applied to the time elapsed due to the parking rate changes that w ent into effect on January 1, The errors w ere caused by edits to the parking system that w ere done to implement the parking rate increase. MAC parking system consultants fixed the issue by January 5th, and no errors relating to the rate change w ere subsequently detected. In addition, a rebate code related to the parking fee change w as misapplied, resulting in a $40 loss. 5

7 Page 7 of 16 Reconcile the various types of exceptions between the payment tables in the Orion System and the sales reports in the Parking Revenue Control System (RCS). There is a mapping issue between the Orion exception table and the RCS report where not all exceptions appear in RCS. HUB Parking is looking into the issue. RECEIPTS PARKING REVENUE Compare payments, rebates, exception tables, and counts to the amounts and quantities shown on the sales reports. This section focuses on tying out the sales figures to the sales amounts shown in the payments table. Trace cash, check and credit card transitions shown in the parking revenue management system to the entries shown in E1 and the bank settlement statements. Review the Orion Credit Card Payments without Station Acknowledgment report to determine whether the transactions on this report were listed in the sales reports and were processed through Heartland Payment Systems. No material errors were discovered while tracing the sales from the tables to the amounts on the sales reports. Parking System activity was reconciled to the E1 journal entries, Heartland (HPS) and American Express (AMEX) settlement statements. The differences between auditor calculations and Parking Management calculations were immaterial. The number of items appearing on the Credit Card Payments without appearing on the Station Acknowledgement reports was immaterial. The dollar amounts involved were also immaterial. GROUND TRANSPORTATION (TAXI, SHUTTLE, PARKING) Validate that cash and check payments recorded in MAVIS for all revenue types (Taxi, Shuttle, Based on the review procedures Employee Parking) are accurately performed, no material variances recorded in E1. were identified. Validate that credit card payments recorded in MAVIS for all revenue types (Taxi, Shuttle, Employee Parking) were accurately recorded in E1. Review the use of parking privileges extended to MAC employees to ensure that they are used for MAC business purposes. Review all fee changes to ensure that they are entered by an authorized individual. Based on the review procedures performed, no material variances were identified. Employee parking stays greater than 24 hours were identified using data analysis. Transactions were reviewed for proper approval. No exceptions noted. All fee changes were entered by an authorized individual and approved by the Commission. No exceptions noted. 6

8 Page 8 of 16 Beginning in first quarter 2017, MAC Internal Audit will perform quarterly review of Transportation Netowork Companies (TNC) activity at MSP as part of our continuous auditing program. MAC Ordinance 124 established a $3.00 trip fee for each billable transaction. RECEIPTS GROUND TRANSPORTATION (TRANSPORTATION NETWORK COMPANIES, aka TNC) Validate that the monthly payments received from each TNC reconcile to the trip activity occurring within the defined Airport geo-fence boundary. Validate that the TNC Billing Report reconciles to the TNC wire payment. Validate that TNC payments are uploaded into E1 accurately. Uber - Some records were not reported due to a cut-off issue, resulting from the time difference between UTC and Central Time. Other records were underreported, representing an amount due to MAC. Lyft - For January and February, there was an underreporting of some transactions that Lyft claims were cancelled transactions. Landside is determining whether cancelled transactions should be collected. Beginning with March, Lyft is providing documentation of cancelled transactions. Uber - For January and February, there was an underpayment of $4,182 due to a calculation error. The amount due was included in their March payment. Lyft - No issues noted. TNC payments were recorded in E1 accurately. No exceptions noted. Validate that all TNC transactions occur within the defined Airport geo-fence boundary. TNC transactions occurred within the defined Airport geo-fence boundary. No exceptions were noted. Note: As of June 23, In total, Uber has $3,219 in outstanding underpayments that have not been reimbursed to the MAC for Q Lyft has $858 in outstanding underpayments that have not been reimbursed to the MAC for Q Landside is following up with Uber and Lyft regarding the underpayments. 7

9 Page 9 of 16 Obtain data files from each of the Auto Rental Concession operators that list each rental transaction broken down by revenue type for each month of the quarter. Review transactions from month to month for reasonableness. For 3 out of 4 companies, revenue types and totals appeared reasonable and consistent with past periods. A potential issue was noted in one company, see note below. RECEIPTS AUTO RENTAL Using detailed transaction data files, recalculate revenue totals for each operator for each revenue type in each operating location. Compare recalculated totals to revenue reports and payments submitted by each operator. Using detailed transaction data files, perform an analytical review of daily revenue reported by each operator in each location. Identify missing days and unreasonable fluctuations in reported revenue. Review customer facilities charges recorded for each rental transaction. Recalculate total charges collected and passed through to MAC. No material differences were identified. Minor differences were found due to timing differences between report types. No missing days or unreasonable or unusual fluctuations in daily revenue were identified. No material differences in calculations or passed through amounts were identified. Review adjustments to revenue collections for accurate calculation and reasonableness. Minor adjustments to gross sales were reviewed and were found to be accurate and reasonable. Review airport concession fees that were charged to customers to reimburse auto rental operators for the percent rent that is payable to the airport. Review calculations to ensure compliance with lease terms. Airport Concession fees were properly calculated and reported to MAC. Note: Beginning in February 2017, it appears that one company has underreported "Vehicle Licensing Fee" (VLF). However, this issue did not immediately affect the monthly rental amount due. The lease manager has asked the car rental company to investigate the issue. 8

10 Page 10 of 16 RECEIPTS FOOD AND BEVERAGE / RETAIL / VENDING On a sample basis, obtain data files and detailed reports from the Concession Management Firms listing daily sales by account code for selected concession unit(s) for each business day for the period being reviewed (ie, month). Review transaction totals for completeness and reasonableness. On a sample basis, using operator data files and reports, recalculate revenue totals for selected operator(s) for selected operating location. Compare recalculated totals to revenue reports submitted by operator(s) and payments submitted to MAC. On a sample basis, review reports prepared by subtenants for subtenant unit(s) selected for review. Compare to general ledger and reports provided by the corresponding Concession Management Firm. On a sample basis, review calculations and payments of utility and consortium fees paid by concession tenants. For the sample reviewed, reports and data appeared to be complete. Totals were reasonable when compared to past periods. For the sample reviewed, no material differences were identified. For the sample reviewed, no missing days or unreasonable or unusual fluctuations in unit sales were identified. For the sample reviewed, no material differences were identified. ACCOUNTS RECEIVABLE Obtain revenue transaction data by account. Analyze revenue trends by month over a 5 year span. Differences reviewed were Investigate material differences and reasonable or explained through review samples of outliers. further investigation. Obtain revenue transaction data by payee. Analyze revenue trends by month over a 5 year span. Investigate material differences and review samples of outliers. Differences reviewed were reasonable or explained through further investigation. 9

11 Page 11 of 16 Obtain payment transaction data by account. Analyze spending trends by month and compare to the prior 5 year span. Investigate material differences and review samples of outliers. Differences reviewed were reasonable and explained through further investigation. Obtain payment transaction data by vendor. Analyze spending trends by month and compare to the prior 5 year span. Investigate material differences and review samples of outliers. Differences reviewed were reasonable or explained through further investigation. DISBURSEMENTS ACCOUNTS PAYABLE Isolate payments to professional service providers and analyze payment trends for possible fraud or errors. Review payments for compliance with MAC Policies. Isolate payments related to capital projects. Compare adjusted capital project budgets approved by the Commission to total payments issued for each project to date. Using a Benford Analysis program, select various departments and/or payment types for review. Look specifically for amounts that fall outside the expected ranges and review to determine if further testing is needed. Payments to professional service providers were reviewed and compared to similar payments for each service provider over a five year period. Professional Service Authorizations were reviewed for compliance with policies. No errors were detected and no further testing was needed. Payments appeared reasonable. Total payments for each project were within project budget amounts authorized by the Commission. Sample groups of payments falling outside of the Benford Model were identified and reviewed. Samples were selected for testing. All samples from groups falling outside of normal distributions were adequately explained. Semi Annually Download Enterprise One procurement transactions. Analyze the data looking for trends and/or evidence of potential noncompliance with MAC purchasing policies or state purchasing laws. We isolated instances of multiple requisitions on the same timeframe to the same vendor by the same person that in total exceeded the threshold for which Commission approval is required (was $50,000-- raised to $100,000 on February 21, 2017). After further investigation, no exceptions were identified. 10

12 Page 12 of 16 Review listing of active cardholder accounts and reconcile to employee master file to ensure that cardholders are authorized active employees. All cardholder accounts were held by authorized MAC employees or other authorized staff. DISBURSEMENTS PURCHASING CARD PAYMENTS Reconcile purchases recorded on the US Bank System to purchases on the MAC Accounting System. Summarize all transactions by Merchant Category Code and by Merchant. Select transactions coded to unusual merchant groups or transactions with merchants posing a higher risk of being personal use purchases for further testing. Review transaction detail for purchases greater than $3,000, which are only allowed with special authorization. Examine multiple purchases by the same cardholder with the same vendor which could be used to circumvent the $3,000 spending limit. Perform a Benford Analysis and review transactions that appear to fall outside of normal trends. Identify P-Card purchases occurring on weekends which could indicate that they were made for a nonbusiness purpose. Validate that transactions were made for legitimate business purposes. US Bank transactions were fully reconciled to the MAC Accounting System. Sample transactions were identified for further analysis and testing. A few transactions were not adequately documented and required further review. No issues were identified. Transactions over $3,000 were identified for further review. In each instance, sample transactions appeared to have a legitimate business purpose. Several purchases were identified for further testing. After further review, the transactions tested were found to be in compliance with MAC Policies. After further review, it appeared that all sample transactions could be traced to proper authorization and a valid business purpose. Weekend purchases were isolated from the transaction data and received further review. No exceptions were noted. Identify and test travel and business expense purchases that are made using MAC Purchasing Cards. Compare employee expense reimbursements to Purchasing Card payments to identify possible duplications. Review purchases for compliance with policies. Validate that automotive purchases were for MAC-owned vehicles. No issues were identified. Note: During first quarter 2017, US Bank P-card data indicated 240 transactions were charged with sales taxes, totaling $5,451. Based on the review of the transactions indicated, 122 should have been considered exempt from sales tax, resulting in an overpayment of $2,198. Based on discussions with Finance and several individual cardholders, efforts are in progress to recoup the overpaid taxes and issuing the certificates of exemption to the appropriate vendors. 11

13 Page 13 of 16 Obtain payroll data for the current month by business unit and pay code and compare it to the same month for the preceding two years. Select a sample of business units for further testing. Variations in payroll from prior periods as well as variations from budget estimates were examined. All significant variances appeared reasonable after further investigation. No exceptions were noted. Review employee pay adjustments for reasonableness and select a sample of employee pay increases for further testing. For each of the increases selected, verify that they were properly approved and in compliance with policies and applicable labor agreements. After performing our pay rate adjusment testing, pay rate adjustments that appeared unusual were investigated in detail on a sample basis. All samples were properly documented, approved and in compliance with policies and labor agreements. DISBURSEMENTS EMPLOYEE PAYROLL Verify that new hires and terminations of employees are appropriately documented and approved. A sample of new hires and terminations was reviewed. The items tested were properly documented and approved. Perform an analysis of overtime pay. Select a sample of employees that received overtime pay and verify that the overtime was properly An analytical review of overtime hours calculated and approved and was was performed for each month of the in compliance with the relevant quarter. Sample employees were labor agreements and/or state and selected for further review. No federal wage laws. exceptions were noted. Detailed payroll data from Workforce Director was obtained for a sample of employees. Data was reconciled to supporting documentation and to the Test sample transactions from the E1 Payroll Module to ensure that Workforce Director (WFD) System hours were properly recorded and that is used for scheduling and time accurately paid. Sample employees recording for certain hourly were reviewed to ensure hours paid employees. Ensure that hours were were properly documented. No accurately recorded in WFD. exceptions noted. Perform a year-end analysis of total leave hours and other hours paid in each pay type recorded for each employee. Determine whether annual totals for each employee within each leave type are within policy limits and to ensure that pay types restricted to certain employee groups are not recorded for employees outside of those groups. No material errors were found. Annually 12

14 Page 14 of 16 DISBURSEMENTS EMPLOYEE BENEFITS Review MAC and Benefit Administrator records to determine whether employees are enrolled in benefit programs for which they are qualified and have selected. Match Commission approved benefit premiums against actual amounts withheld from employee payroll for each covered employee and dependents. Match employee contributions to deferred benefit programs from payroll withholding against contributions received by the benefits administrator. Match authorized retirees qualified for benefits and authorized rates against benefit premium payments to MAC and benefit provider enrollment listings. No issues were identified this quarter. No issues were identified this quarter. No issues were identified this quarter. No issues were identified this quarter. GENERAL ACCOUNTING ADDRESS BOOK Match vendor addresses to employee or ex-employee addresses and review any payments made to vendors with matching employee or ex-employee addresses. This is a test to detect possible fraud or conflict of interest. Semi -annual testing was completed in the first quarter. Our computer analysis identified some potential matches. After further investigation, we found that all payments appeared to be reasonable and appropriate. Review Address Book entries by User ID to see if only authorized employees have made entries. Access to make new entries in the address book should be limited to the greatest extent practical. Those New entries for the quarter appeared with address book access should reasonable and access to enter new not have access to issue payments. addresses was properly restricted. Review changes to the Address Book to determine whether address changes and additions of employees, vendors and customers appear reasonable and are approved by appropriate staff. No unusual entries were detected. Semi-Annually 13

15 Page 15 of 16 SYSTEM ACCESS Summarize the transactions within the AR, AP, and GL tables by UserID and review the User IDs to ensure these employees were allowed to make entries within these areas, and that assigned access fits with their job duties. Test a sample of new hires and terminated employees to ensure access was either properly granted or removed. No errors were detected while reviewing the user IDs for the quarter. No errors were detected. Semi- Annually GENERAL ACCOUNTING CHANGE MANAGEMENT BANK RECONCILIATIONS JOURNAL ENTRIES INVESTMENTS Test a sample of system changes to ensure that changes were adequately tested, approved, and documented. No errors were detected. Obtain the operating account monthly bank reconciliations and verify that the reconcilations are complete and properly approved. No errors were detected. Ensure that bank balances are properly reconciled to the accounting records for each period. No errors were detected. Review reconciling items to ensure that they are properly cleared in the succeeding period. No errors were detected. Review a sample of journal entry adjustments to account balances. Ensure that entries are reasonable and properly approved. No errors were identified. Sumarize all journal entry adjustments by User ID and Transaction Originator. Determine whether entries were made by appropriate staff. No errors were identified. Review monthly investment reconciliations performet by MAC Finance Dept. Verify the sufficient collateral is pledged for MAC investments. Review compliance with MAC Investment Policy. Not tested this quarter - to be tested in 2nd and 4th quarter. Not tested this quarter - to be tested in 2nd and 4th quarter. Not tested this quarter - to be tested in 2nd and 4th quarter. Note: Each year (usually in December or January), there is an E1 user access report that is run and disseminated to the business owners such as Finance and Purchasing. Management reviews it and requests changes to ensure that the level of access is appropriate for each user. This report was not issued during the first quarter, so the user access report has not been reviewed by the business owners since December Audit was informed that the report will be issued soon and will report on the results of the review next quarter. Semi-Annually Semi-Annually 14

16 Page 16 of 16 SUMMARY OF CONTINUOUS AUDIT RESULTS All continuous audit testing for the first quarter of 2017 was completed as planned. Automated scripts were run in planned areas and the resulting data files and reports were carefully reviewed by Internal Audit staff. The review process raised multiple questions and concerns for further review. Each potential issue was documented in the audit work papers and additional reviews were conducted by assigned Internal Audit staff. For the period of January 1 through March 31, 2017, we found no significant issues that, in our opinion, would require a request for Commission action at this time. All minor issues identified have been addressed with the appropriate parties and will be reviewed and monitored in the months going forward. Regular meetings between Internal Auditors and staff in key areas are conducted to address ongoing concerns. Results of current tests will be considered in developing new testing and in refining existing tests. We would like to thank MAC Staff and the staff of MAC s business partners for their cooperation in providing transaction data, answering questions and providing additional information related to possible issues identified in our audit testing. Sincerely, Scott Zaczkowski, CIA/CFE/CRMA Director, Internal Audit CC: Tom Anderson Steve Busch Roy Fuhrmann Patrick Hogan Jim Laurent Mitch Kilian Dennis Probst Bridget Rief Bob Schauer Eduardo Valencia 15