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B-213761 1 (1984-07-27)

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                COMPTROLLER GENERAL OF THE UNITED STATES
                               WASHINGTON D.C. 20648


                                                           124800

B-21 3761                               July 27, 1984



The Honorable Thomas E. Petri

House of Representatives

Dear Mr. Petri:

     By letter report dated December 12, 1983, we supplied you
with cost information concerning the Department of Agriculture
(USDA) tobacco price-support program. 1/ As we noted in that
report, our audit staff found variances between the procedures
used by the Department of the Treasury in charging interest
and crediting repayments against loans to the Commodity Credit
Corporation (CCC) and those procedures employed by CCC in
charging interest and crediting repayments on loans to tobacco
producer associations. The most significant variance is that
Treasury charges CCC interest on the daily outstanding balance
it owes Treasury, including accrued but unpaid interest from
prior periods; however, CCC does not charge its producer asso-
ciations for accrued interest. The impact of this and other
variances between CCC and Treasury procedures is a net loss to
CCC based on the difference between the amount of interest
collected by CCC from tobacco producer associations and the
corresponding interest which CCC pays the Treasury for bor-
rowed funds. This net loss is funded through annual appropri-
ations to CCC.

     This letter analyzes whether the Secretary of Agriculture
is required, under either the Food and Agriculture Act of 1981
(the 1981 Act), Pub. L. No. 97-98, 95 Stat. 1266, Decem-
ber 22, 1981, or the No Net Cost Tobacco Program Act of 1982
(the 1982 Act), Pub. L. No. 97-218, 96 Stat. 197, July 20,
1982, to change CCC's procedures for charging interest and
crediting loan repayments to make them consistent with the
procedures used by Treasury in order to eliminate CCC's inter-
est losses. Although the issue is not free from doubt, we
conclude that the Secretary is not so required.

     In our view, the 1981 Act and the 1982 Act must be con-
strued together. While both the 1981 and 1982 Acts generally
indicate that Congress intended the tobacco program to operate
at no net cost to the taxpayers, the 1982 Act's legislative
history indicates that Congress did not view either Act as

1/   Cost Information on USDA's Tobacco Program, RCED-84-33,

     December 12, 1983.

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