Office of Inspector General

The Bureau Could Not Demonstrate That Its Founding Was Authorized

OIG-2026-02 FINDING UNRESOLVED. RECOMMENDATION CLOSED. CAP Rev. 12.4

Document type

Inspector General report

Issuing office

Office of Inspector General

Closure status

Finding unresolved. Recommendation closed.

Public impact

Level 5, Continuity

Published

July 28, 2026

Why the review was initiated

The Office of Inspector General initiated this review after CASE HAEB-1908-NULL reported that the Continuity and Prior Events Act of 1908 could not be produced from any Bureau holding.

The case remains under prior review. This review examines the controls that were expected to prevent that condition.

Objective

To determine whether HAEB can demonstrate that it was lawfully created, and whether the Bureau’s controls over founding documentation are adequate to locate, retain, and produce that documentation.

Scope and methodology

We searched the Bureau’s holdings, the archive index, the register of publications, and the Official Record under Revision 12.4. We reviewed CASE HAEB-1908-NULL, the Bureau’s published history, and the authorities page. We interviewed the Office of Internal Historical Affairs, the Office of Records That Should Not Exist, and the Office of the Administrator.

One collection was identified during the review and not searched. The office of record for that collection does not appear on the Bureau’s organization chart, and our access request was returned as misaddressed.

Background

The Bureau’s claimed founding is 1908. The claimed authority is the Continuity and Prior Events Act of 1908. The Bureau’s seal states that it has served the Republic since 1789, effective retroactively.

The Bureau operates under three amendments to the Act. The earliest is dated 1791. One takes effect upon necessity and carries no date.

The Bureau’s 2026 performance dashboard reports founding authorities independently verified as 0 of 1.

Findings

Finding 1. The Act could not be located

We did not locate the Continuity and Prior Events Act of 1908 in the Bureau’s holdings, in the archive index, in the register of publications, or in the Official Record.

The Bureau has not located it in 118 years.

Finding 2. The item cataloged as the Act is empty

Archive item EV-1908-0 is cataloged as the Continuity and Prior Events Act of 1908. The item is a folder. The folder contains no document. The catalog record is complete in every required field.

The Office of Records That Should Not Exist advised that it describes records and does not maintain a field in which the absence of a described record can be recorded.

The Office’s finding is that the record is complete. We do not dispute the finding. We could not test it.

Finding 3. The Bureau maintains no central index of founding authorities

The Bureau maintains registers for cases, forms, directives, advisories, offices, personnel, and redactions. It maintains no register of the authorities under which those registers are kept.

The absence has been reported in each prior review of this subject. We could not determine how many prior reviews there were.

The series index lists three reports. Two are published.

Finding 4. The Bureau’s review of the founding predates the founding

CASE HAEB-1908-NULL remains under prior review. The memorandum opening that review is dated March 4, 1906, two years before the founding it reviews. The Bureau has recorded the memorandum as the authorization for the docket.

The memorandum carries a custody signature. The signing party is recorded as Employee 000. No personnel record exists for that employee.

We report the records as we found them.

Evidence

1. EV-1908-0. Empty archival folder cataloged as the Continuity and Prior Events Act of 1908. Retention: permanent. Access: open.
2. EV-1908-NULL-01. The 1906 memorandum requesting a search for the Act. The authority cited in the memorandum is withheld. The custody signature is recorded as Employee 000.
3. Register of publications, 1908 through 2026. No entry for the Act. Eleven entries cite it.
4. Amendment file. Three amendments in force. The earliest is dated 1791. One takes effect upon necessity and carries no date, and was therefore in force during our review.
5. Access request, returned. Addressed to the office of record for the unsearched collection. Returned marked as misaddressed.

Impact

The Bureau has operated for 118 years under an authority it cannot produce.

During the reporting period the Bureau issued 312 pages of guidance, reviewed 318 incidents, certified 8,442 completed events as remaining complete, and reported public recollection alignment of 94.2 percent.

Each of those activities cites the authority described in Finding 1.

Recommendations

1. We recommend that the Office of Internal Historical Affairs establish a central index of founding authorities.
2. We recommend that the Bureau document a standard definition of “located.”
3. We recommend that founding document control be addressed in mandatory annual training.

Management response

Management concurs in principle.

Management does not concur with the characterization in Finding 1, and offers, as evidence that the Bureau was lawfully created, that the Bureau exists.

Management notes that a central index of founding authorities would require the authorities to be located before the index could be populated, and that locating them is the purpose of the index.

Management further notes that the Act’s absence from the approved record is consistent with the withholding controls the Act established, and asks that the absence be recorded as evidence that those controls remain effective.

Recommendation 1 has been assigned to the Office of Internal Historical Affairs, which the Act created. The estimated completion date was September 30, 2024. The index has been established and contains 0 of 1 entries.

OIG comment

Recommendation 1 is closed. The index exists and is empty.

Finding 1 remains unresolved. Resolution requires the Act.

The Office of Inspector General does not question the Bureau’s existence.

Closure status

Finding 1 unresolved. Findings 2 through 4 unresolved. Recommendation 1 closed. Recommendations 2 and 3 open.

This report was transmitted to the Office of the Administrator, who has held the position in an acting capacity since 1974 and who signed the Bureau’s response.

R. Morrow Inspector General