Appendix B USDA Information System Security Program Directive

March 31, 2006

DM 3545-002

CHAPTER 9, PART 2
USDA INFORMATION SYSTEMS SECURITY PROGRAM
1

BACKGROUND
On January 23, 2002, Congress enacted Public Law, 107-347, EGovernment Act of 2002. The Federal Information Security
Management Act (FISMA) of 2002, Title III, of this law requires that
each agency have effective information security controls over
Information Technology (IT) to support Federal operations and
assets and provide a mechanism for improved oversight of
Federal agency information security programs. This Act was
designed to strengthen OMB Circular A-130, Appendix III that
initially established specific requirements for all agency security
programs. As technology has grown more complex and open,
the need for effective Federal information security programs in
each agency and staff office is essential. In USDA, this program
is referred to as the Information Systems Security Program (ISSP).
USDA has undertaken an aggressive role in support of E-gov to
include ensuring that IT systems have been certified and
accredited or otherwise authorized as being properly secured.
All of these actions require that each agency ISSP be responsive
and responsible in supporting security requirements. The material
in this chapter is designed to outline the responsibilities of each
agency and staff office ISSP and to specifically define the
security roles of the Agency Administrator or Head, Chief
Information Officer (CIO) and Information Systems Security
Program Manager (ISSPM). These positions are vital
components in securing USDA corporate information technology
assets by providing effective agency management and
oversight of its ISSP.

2

POLICY
All USDA agencies and staff offices will organize, implement and
maintain an ISSP that ensures security of all information
technology assets. Security must be adequately addressed in all
phases of the System Development Life Cycle (SDLC), normally

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commencing in the IT System Initiation Phase. Each agency ISSP
will include the following responsibilities:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Categorize sensitivity of information and information systems
in accordance with FIPS 199;
Conduct regular risk assessments for IT systems and
computing devices;
Implement effective risk mitigation strategies;
Conduct formal Certification and Accreditation (C&A) of all
agency IT systems;
Implement security controls throughout the System Life Cycle;
Use the Capital Planning and Investment Controls (CPIC)
process to formulate and plan security costs for all systems;
Monitor the system Configuration Management (CM) process
of all systems;
Prepare agency annual Program and System Specific
Security Plans;
Manage an effective Security Awareness and Training
Program;
Manage the agency Security Incident Response Program;
Conduct annual self-assessment of the ISSP using NIST 800-26
and NIST 800-53;
Monitor IT systems using audit trails, controls logs and other
mechanisms;
Establish an electronic inventory of all IT systems and
computing devices;
Maintain agency IT inventory in the Enterprise Architecture
Repository (EAR);
Disseminate department policy and procedures to all agency
personnel;
Respond to regular and ad hoc reporting requirements and
audits by internal or external agencies; and
Monitor agency compliance to USDA, OMB, NIST and other
governing bodies’ policy for security.

Agencies may elect either a traditional ISSP structure with the
responsibilities delineated in Responsibilities, Section 4, of this
policy or use the alternative structure defined in Procedures,
Section 3 below. An alternative structure is useful in agencies of
greater than 1,000 IT users (employees, contractors, volunteers,
partners, or customers), as it outlines the tactical security

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responsibilities below the ISSPM level. The duties of the
ISSPM/ISSM can be designated as the agency sees fit, as long as
all responsibilities are designated in writing and effectively
executed. Associate CIO for Cyber Security (ACIO CS) must be
advised that the alternative structure is being implemented and
each agency must comply with the duties defined for this
structure.
Each Agency Head or CIO will formally designate at least one
Information Systems Security Program Manager (ISSPM) using the
Designation of ISSPM and Deputy ISSPM form contained in
Appendix A to serve in these positions. These forms will be sent
to the ACIO CS when individuals are assigned to these positions.
The duties and responsibilities of an ISSPM are diverse,
comprehensive and complex. This position is one of high
sensitivity and level of trust and therefore will be filled only by full
time government personnel. In addition, this position has a
requirement for high confidentiality due to the critical nature of
the investigatory and compliance work. Therefore space should
be assigned to the ISSPM and Deputy ISSPM that affords locking
files and the ability to conduct meetings of a highly sensitive
nature in private. In no case, are ISSPMs and Deputy ISSPMs to
be assigned to a work/office area with individuals not
associated with information security. To successfully establish,
manage and improve an agency/staff office/program area
ISSP, the ISSPM shall receive comprehensive annual security
training. Agencies/staff offices/program areas shall appoint a
Deputy ISSPM and as many Information Systems Security Officers
(ISSOs) as necessary to comply with this policy. The agency
ISSPM shall be recognized as the organization’s CS expert, leader
and point of contact. The agency ISSPM, Deputy ISSPM and
ISSM/ISSO positions are considered to be High Risk Public Trust
positions as defined by 5 CFR 731. Each agency will ensure that
the individuals in these positions have the appropriate level of
background investigation completed. Additionally, each
agency is responsible for determining the National Defense
sensitivity level of these positions as defined in 5 CFR 732 and
obtaining the appropriate level of security clearance.
Individuals in these positions will have a direct reporting
relationship with the agency CIO.

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Policy Exception Requirements – Agencies/Staff Offices and
program areas that cannot comply with this policy will submit all
policy exception requests directly to the ACIO CS. Temporary
exceptions to policy will be considered only in terms of
implementation timeframes and progress toward meeting the
standards will be monitored by OCIO CS. Exceptions that are
approved will require that each agency report this Granted
Policy Exception (GPE) as a Plan of Action & Milestone (POA&M)
in their FISMA reporting, with a GPE notation, until full compliance
is achieved. Interim exceptions expire with each fiscal year.
Compliance exceptions that require longer durations will be
considered for renewal on an annual basis with an updated
timeline for completion. OCIO CS will monitor all approved
exceptions.
3

PROCEDURES
Agencies and staff offices electing to adopt a three-tier ISSP
management approach will have a structure comprised of:
•

•

Information Systems Security Program Manager (ISSPM):
This person and the deputy ISSPM are responsible for
managing the ISS efforts for an entire agency or staff
office. This person is a program manager responsible for
the strategic security requirements of the program to
include planning, budget review, consolidation of agency
security reports, and coordination of the ISSP into the
culture of the entire organization. ISSPMs will act as
consultants for ISSM/ISSOs and work with them to resolve
highly technical matters, when necessary. Ultimately, the
ISSPM is still responsible for efficient operation of the
overall ISSP.
Information Systems Security Manager (ISSM): This
individual(s), including deputy(ies), is responsible for
managing the tactical efforts of a business, functional, or
operational entity within an agency. Their responsibilities
include the daily operational security issues of the unit and
overall management of the “front line” security
requirements for the unit. This individual may often be

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•

a

called upon to assist in the resolution of certain system
security issues.
Information Systems Security Officer (ISSO): This person(s),
including deputy(ies), is responsible for the day-to-day
security administration for one or more information
systems. Theirs is an operational security effort regarding
the system(s) for which they are responsible.
RESPONSIBILITIES (Alternate)
(1)

The Agency Chief Information Officer (CIO) will:
(a)
(b)
(c)
(d)
(e)

(f)

(g)

(2)

Act as the agency Senior Security Officer
(SSO) who is responsible for supporting the
strategic requirements of the ISSP;
Ensure that adequate funding, training and
resources are provided to the ISSP to support
the agency mission;
Facilitate the resolution of high-level security
matters within the agency by acting as a
champion for the ISSPM;
Ensure that ISSM/ISSOs are designated to
provide adequate security to business,
functional or operational entities;
Serve as the certification official for agency
security requirements (i.e., Annual Security
Plans, FISMA and other formal reporting
requirements, Waiver Requests and
Certification of agency IT Systems);
Formally designate in writing to ACIO CS the
ISSPM(s) and Deputy(ies) for each agency;
ensure that these individuals are permanent
members of all system development,
telecommunications planning and System
Development Life Cycle planning teams; and
Provide role-based and specialized securitybased training to the ISSPM(s) and Deputy
ISSPM(s) from USDA enterprise training
vehicles.

The Agency Information Systems Security Program

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Manager (ISSPM) will:
(a)
Manage the agency ISSP including the
activities and training from USDA Enterprise
training vehicles of the ISSM/ISSOs;
(b)
Support the strategic security program
requirements to include: planning, budget
analysis, department policy review and
internal policy formulation, agency FISMA,
POA&M, and audit reporting requirements,
agency Security Architecture and agency IT
CPIC;
(c)
Consolidate individual reports from all
functional and operation units into one
agency combined report (i.e., monthly scans,
patches, incidents) for higher level
management, including ACIO CS;
(d)
Monitor the progress of the ISSM/ISSOs to
ensure that they meet the necessary program
security requirements of NIST 800-26 and
departmental policy directives;
(e)
Serves as the principle consultant to the
agency CIO and senior management,
including ACIO CS;
(f)
Coordinate agency Incident Response with
the agency ISSM/ISSOs to include all
associated actions necessary to mitigate the
risk to unit systems; and
(g)
Oversee the implementation of agency
security policies, procedures and guidelines.
(3)

The Agency Information Systems Security Manager
(ISSM) will:
(a)
(b)

Serve as the Point of Contact (POC) for all unit
CS matters; provide subject matter guidance
to agency personnel;
Participate in the process and monitor to
ensure that all agency systems are C&A’d
prior to actual operation and that they are
reaccredited every three years or when
significant system change occurs;

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(c)

(d)

(e)
(f)

(g)

(h)
(i)

(j)

(k)

Disseminate departmental security policy and
procedures; formulate internal agency
security procedures and support
implementation, testing, and integration into
the agency culture (mission and business
operation);
Participate as a permanent member of unit
system development teams,
telecommunications planning, and System
Development Life Cycle (SDLC) processes;
Conduct internal audits of all agency IT
systems to ensure compliance with federal
and departmental policy and procedures;
Participate in general and role-based security
training to enhance knowledge and skill level;
recommend appropriate training for staff to
ISSPM;
Proactively coordinate the establishment of
system security controls to protect agency
information using authentication techniques,
encryption, firewalls, access controls, and
comprehensive departmental Incident
Response Procedures with all System
Administrators (SA) and business owners;
Coordinate with business owners to
categorize information systems and determine
sensitivity levels;
Establish Disaster Recovery/Business
Resumption (DR/BR) and other emergency
plans for all IT systems; ensure compliance
with backup and storage procedures;
Monitor physical spaces to ensure that the
security requirements of IT Restricted Space
are followed in maintaining, updating or
planning new space, and advise the CIO if
space does not meet security requirements;
Develop and manage a Security Awareness
Program including arranging or conducting
security awareness briefings; recommend to
the agency ISSPM security training for all
agency personnel, including contractors,

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(l)

(m)
(n)

(o)
(p)

(q)

(r)
(s)
(t)

(u)

based on their role in the organization; ensure
that all personnel are appropriately trained in
the security Rules of Behavior prior to being
granted access to unit systems;
Arrange for background screening of unit
employees based on the level of trust and
sensitivity of the position they occupy in the
organization;
Participate in the development of an agency
security architecture for all IT systems;
Monitor and coordinate patch management
and scanning techniques for all unit systems;
participate in identification and mitigation of
all system vulnerabilities,
Coordinate the provision of security controls
for Portable Electronic Devices (PEDS) and
other wireless technology;
Participate in the Overall Agency Security
Plan for the program and coordinate with
Information Systems Security Officers (ISSO) to
ensure that current system specific plans are
in place for all IT systems; coordinate or
participate in risk assessments of all unit
systems and mitigate vulnerabilities;
Monitor CM practices to ensure that security
controls are maintained over the life of the IT
systems, and formulate and prepare an
electronic agency inventory for unit
computing devices;
Monitor and participate in assessments to
ensure that Privacy requirements are met;
Plan and document security costs for unit IT
investments and systems;
Prepare and update reports to ensure that
the unit complies with mandated internal and
external security reporting requirements,
including FISMA and CPIC;
Proactively participate in new CS initiatives
including, but not limited to, computer
investigations and forensics; and

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(v)

4

Prepare and coordinate unit Incident
Responses with the agency ISSPM to include
all associated actions necessary to mitigate
the risk to unit systems.

Agency Information Systems Security Officers (ISSO)
will:
(a)

(b)

(c)

(d)
(e)

Be knowledgeable of Federal, Departmental,
and agency security regulations when
developing functional and technical
requirements; serve as a POC for system users
with security issues;
Coordinate security program and system
elements with the agency IT Program
Managers by evaluating system environments
for security requirements and controls
including: IT Security Architecture, hardware,
software, telecommunications, security trends,
and associated threats and vulnerabilities;
Manage security controls to ensure
confidentiality, integrity and availability of
information; build security into the system
development process and define security
specifications to support the acquisition of
new systems; review and sign off on system
procurement requests to ensure that security
has been considered and included;
Assist with security controls and associated
costs in the CPIC Process;
Assist the ISSM in the C&A process, including
updates to the overall Agency and System
Security Plans (SSP) for the program; serve as a
key advisor in risk assessments of all systems
and mitigate vulnerabilities; adhere to CM
practices to ensure that security controls are
maintained over the life of IT systems; update
the electronic agency inventory for all
agency computing devices;

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(f)

(g)
(h)

(i)

(j)
(k)

4

Adhere to and implement system security
controls that ensure the protection of Sensitive
But Unclassified (SBU) information using
authentication techniques, encryption,
firewalls, and access controls;
Assist the ISSPM in following Department
Incident Response Procedures;
Assist the system owner and ISSM in the
development, testing and maintenance of
agency and system contingency plans,
backup and storage procedures; document
all procedures according to departmental
and agency standards;
Audit and monitor application, system and
security logs for security threats, vulnerabilities
and suspicious activities; report suspicious
activities to the agency ISSPM;
Support and facilitate the security awareness,
training and education program; and
Assist the ISSM in any other security related
duties, as required.

RESPONSIBILITIES
a

The Associate CIO for Cyber Security (ACIO CS) will:
(1)

Act as the recognized Senior Security Officer (SSO)
for the department and the central point of contact
for CS management within USDA;

(2)

Formulate and issue departmental CS policies and
procedures for all USDA agencies and staff offices;

(3)

Promote and monitor C&A of all USDA IT Systems;

(4)

Provide enterprise-wide contractual vehicles and
tools for security products and services;

(5)

Monitor agencies to ensure that all Security Plans
are current for programs and agency IT systems;

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(6)

Ensure that agencies comply with CS policy and
procedures;

(7)

Collaborate in identification of material weaknesses
and assist in formulating mitigation strategies, if
required;

(8)

Centralize the department’s Computer Incident
Response with US-CERT and other computer
emergency response teams;

(9)

Assist agencies in responding to computer fraud
and with the handling of forensic evidence and
investigations;

(10) Ensure that agencies implement and maintain
managerial, technical, and operational security
controls;

b

(11)

Support and promote IT Contingency Planning
efforts;

(12)

Monitor and evaluate physical security within IT
Restricted space;

(13)

Ensure agencies meet Privacy Act requirements;

(14)

Review and make recommendations to the CIO for
all IT Investments and Waiver requests;

(15)

Establish and support a Departmental security
awareness and training program;

(16)

Review requests for exceptions to CS Policy and
Procedures in a timely manner; and

(17)

Act as the central point for preparing regulatory
reports required by FISMA and other legislation.

Agency Chief Information Officer (CIO) will:

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(1)

Establish, implement and provide adequate
resources for an agency ISSP that provides a
comprehensive and proactive security process to
protect agency assets;

(2)

Be knowledgeable in legal and liability issues
surrounding computing devices, the consequences
of security breaches and requirements of executive
accountability for IT systems;

(3)

Ensure that all agency systems are C&A’d prior to
operation and that they are reaccredited every
three years or when significant system change
occurs;

(4)

Ensure that Departmental security policy and
procedures are disseminated; ensure that internal
agency security procedures are implemented,
tested, and integrated into the agency culture;

(5)

Designate in writing, using the form in Appendix A,
an agency ISSPM who is a direct report; ensure that
the ISSPM is a permanent member of all agency
system development initiatives, telecommunications
planning, and SDLC processes;

(6)

Provide general and role-based security training to
the ISSPM and security staff to include field
personnel from USDA enterprise training vehicles;

(7)

Establish and monitor an agency Personal Use Policy
for all computing devices;

(8)

Proactively support the establishment of system
security controls at the USDA’s C2 Level of Trust
and provide protection of SBU information using
authentication techniques, encryption, firewalls,
access controls, and comprehensive Departmental
Incident Response Procedures;

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(9)

Support agency contingency planning efforts by
establishing DR/BR and other emergency plans for
all IT systems;

(10)

Ensure that the security requirements of IT Restricted
Space are followed in maintaining, updating or
planning new space;

(11)

Ensure that all agency personnel, including
contractors, receive security awareness briefings
and training based on their role in the organization;
conduct background screening of all employees
based on the level of trust and sensitivity of the
position they occupy in the organization;

(12)

Support the development of an agency security
architecture for all IT systems;

(13)

Ensure patch management and scanning
techniques are employed to protect, identify and
mitigate system vulnerabilities;

(14)

Provide security controls for Portable Electronic
Devices (PEDS) and other wireless technology;

(15)

Ensure that an overall agency security plan is
prepared for the program and current system
specific plans are in place for all IT systems;

(16)

Conduct risk assessments of all systems and mitigate
vulnerabilities wherever feasible;

(17)

Establish CM practices to ensure that security
controls are maintained over the life of the IT
systems;

(18)

Ensure that all computing devices are captured in
an electronic agency inventory and included in the
Department’s Enterprise Architecture Repository
(EAR);

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c

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(19)

Ensure that agency and Federal Privacy Act
requirements are met;

(20)

Ensure that security costs are planned and entered
in to agency’s annual budget submission for all IT
investments and systems;

(21)

Ensure that the agency complies with mandated
internal and external security reporting
requirements, including FISMA and CPIC;

(22)

Ensure that support is provided for computer
investigations and forensics; and

(23)

Proactively support CS initiatives.

The Agency Information Systems Security Program
Managers (ISSPM) will:
(1)

Serve as the POC for all agency CS matters; provide
subject matter guidance to agency personnel;

(2)

Manage the agency ISSP, including field activities;

(3)

Participate in the process and monitor the program
to ensure that all agency systems are C&A’d prior to
operation and that they are reaccredited every
three years or when significant system change
occurs;

(4)

Disseminate Departmental security policy and
procedures; formulate internal agency security
policies, procedures and support implementation,
testing, and integration into the agency culture
(mission and business operation);

(5)

Participate, as a permanent member, on all agency
system development teams, telecommunications
planning, and SDLC processes;

(6)

Conduct internal audits of all agency IT systems to

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ensure compliance with federal and departmental
policy and procedures;
(7)

Participate in general and role-based security
training to enhance knowledge and skill level from
USDA Enterprise training vehicles; recommend
appropriate training for staff and field personnel
from USDA Enterprise training vehicles and other
sources to CIO;

(8)

Proactively coordinate the establishment of system
security controls at the USDA’s C2 Level of Trust; the
protection of SBU information using authentication
techniques, encryption, firewalls, access controls,
and comprehensive departmental Incident
Response Procedures with all SAs and business
owners, and develop security baselines, where
applicable;

(9)

Coordinate with business owners to categorize
information systems and determine sensitivity levels;

(10)

Establish DR/BR and other emergency plans for all IT
systems; ensure compliance with backup and
storage procedures;

(11)

Monitor to ensure that the security requirements of IT
Restricted Space are followed in maintaining,
updating or planning new space, and advise the
CIO if space does not meet security requirements;

(12)

Develop and manage a Security Awareness
Program including arranging or conducting security
awareness briefings; recommend to the agency
CIO security training for all agency personnel,
including contractors, based on their role in the
organization; ensure that all personnel are
appropriately trained in the Security Rules of
Behavior prior to being granted access to agency
systems;

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(13)

Coordinate with local Human Resources Offices to
arrange for background screening of all IT
employees based on the level of trust and sensitivity
of the position they occupy in the organization;

(14)

Participate in the development of an agency
security architecture for all IT systems;

(15)

Monitor and coordinate patch management and
scanning programs for all agency systems;
participate in identification and mitigation of all
system vulnerabilities;

(16)

Coordinate the provision of security controls for PEDS
and other wireless technology;

(17)

Formulate and prepare the overall Agency Security
Plan for the program and coordinate with ISSOs to
ensure that current system specific plans are in
place for all IT systems;

(18)

Coordinate or participate in risk assessments of all
systems and mitigate vulnerabilities;

(19)

Monitor CM practices to ensure that security
controls are maintained over the life of the IT
systems;

(20)

Develop and prepare an electronic agency
inventory for all agency computing devices;

(21)

Monitor and participate in assessments to ensure
that agency Privacy requirements are met;

(22)

Plan and document security costs for all IT
investments and systems;

(23)

Prepare and update agency reports to ensure that
the agency complies with mandated internal and
external security reporting requirements, including
FISMA and CPIC; and

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(24)

d

Proactively participate in CS initiatives including, but
not limited to, computer investigations and forensics.

The Agency IRM, Automation Information System
Management, Operations and Programming Staff will:
(1)

Be knowledgeable of Federal and agency security
regulations when developing functional and
technical requirements;

(2)

Coordinate security program and system elements
with the agency IT Program Managers and ISSPM
(ISSM or ISSO as appropriate) by evaluating system
environments for security requirements and controls
including: IT Security Architecture, hardware,
software, telecommunications, security trends, and
associated threats and vulnerabilities;

(3)

Manage security controls to ensure confidentiality,
integrity and availability of information; build security
into the system development process and define
security specifications to support the acquisition of
new systems;

(4)

Assist with defining security controls and associated
costs in the CPIC process;

(5)

Assist the system owner and ISSPM in the C&A
process, including updates to the overall Agency
and System Security Plans (SSP);

(6)

Participate in risk assessments of all systems and
mitigate vulnerabilities;

(7)

Adhere to CM practices to ensure that security
controls are maintained over the life of IT systems;

(8)

Update the electronic agency inventory for all
agency computing devices;

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(9)

Adhere to and implement system security controls at
the USDA C2 Level of Trust and ensure the
protection of SBU information using authentication
techniques, encryption, firewalls, and access
controls;

(10)

Assist the ISSPM in following department Incident
Response Procedures;

(11)

Assist the system owner and ISSPM in the
development, testing and maintenance of Agency
and System Contingency Plans, backup and
storage procedures; document all procedures
according to departmental and agency standards;

(12)

Audit and monitor application, system and security
logs for security threats, vulnerabilities and
suspicious activities; report suspicious activities to
the agency ISSP Office; and

(13)

Assist the ISSPM in any other security related duties,
as required.
-END-

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Appendix A

APPENDIX A
DESIGNATION OF ISSPM AND DEPUTY ISSPM
Name:_____________________________________
Agency: ___________________________________
GS Series/Title:_________________________________
Level of Background
Investigation:_______________________________________

Location: _______________________________________
_______________________________________
Phone Number: ____________________ Cell Number: ____________________
Fax Number: _______________________ E-mail:__________________________

Agency CIO Name :____________________________

Agency CIO Signature: ____________________________

Date: _____________

A-1