The Contracting Officer and Office of the Chief Financial Officer (OCFO) should establish a comprehensive internal control structure and monitor for compliance. OCFO should ensure that all proper vendor invoice/statement supporting documentation is present before reallocation of clearing accounts. OCFO also recommended that the Director of Procurement Facilities Management review monthly statements. Clarify the policy to explain whether persons other than the Contracting Officer have procurement authority and review the dollar volume of activity to determine reasonable credit limits. At a minimum, annually review potential new and current cardholders for government card red flags. OCFO should periodically review AOPC designations and revise them appropriately. OCFO pointed out that some AOPC designations have not been valid for over two years and will designate the Director of Facility Management as the AOPC on all purchase cards. All purchase cards should have $5,000 single purchase limit and the cycle limit be revised according to usage. Expand the use of merchant code restrictions. NCUA should compare purchase cardholders with a current NCUA employee roster at least annually. OCFO also said the regions have not always notified the office of changes in card ownership due to turnover. NCUA should draft a comprehensive procurement policy and procedure manual. Following completion of the new manual, OCFO should conduct an in-house training session for proper usage and new staff should undergo appropriate training.

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