Mandatory Training for All Personnel Involved in the Administrative Control of Funds to Prevent ADA Violations

1. Purpose. Consistent with directives issued by the Office of the
Secretary of War (Comptroller), the Assistant Secretary of the Navy
(Financial Management and Comptroller), and the Department of the
Navy, this policy establishes mandatory financial-management training
requirements for designated fund control personnel   (references (a)
through (c)).
Fund control personnel play a critical role in the stewardship of
appropriated funds and the protection of taxpayer resources. They are
responsible for ensuring that federal funds are used lawfully,
responsibly, and in accordance with applicable fiscal law,
regulations, and policy.
This training provides Marine Corps personnel with the legal,
regulatory, and procedural knowledge necessary to perform
funds-control responsibilities effectively. It emphasizes the
prevention of Anti-Deficiency Act (ADA) violations, including
obligations or expenditures in excess of available appropriations,
obligations made before funds are legally available, and the
acceptance of unauthorized voluntary services.
ADA violations undermine fiscal discipline, accountability, and
public confidence in the Department of Defense. Completion of the
required training equips FCP to maintain sound financial controls,
prevent legal violations, support audit readiness, and uphold the
integrity of Marine Corps financial management.
2. MARADMIN 350/11 is hereby canceled and is replaced with this
MARADMIN.
3. Definition. The Office of the Secretary of War (Comptroller) 
[OSW(C)] defines key Funds Control Personnel (FCP) as individuals
responsible for ensuring the proper assignment of funds to a
commitment or obligation document before an obligation is incurred.
The Department of the Navy (DON) defines FCP as individuals who issue
and/or accept allocations of appropriated funds and funding 
documents. For Marine Corps purposes, FCP are individuals who issue
and/or accept allocations of appropriated funds and funding 
documents, including work requests, project orders, and similar
documents.
All FCP shall receive written delegated authority through a
Delegation of Authority (DOA) letter. DOAs shall be issued by Deputy
Commandants, Commanding Generals, Commanders, Commanding Officers, or
Comptrollers acting under authority delegated by the applicable CG or
CO, consistent with reference (b).
3.A. To simplify classification, the previous tier system has been
eliminated. Marine Corps personnel performing financial management,
budget execution, or funds-control oversight functions shall be
categorized as either FCP or Non-Comptroller Personnel based on their
assigned roles and responsibilities.
3.A.1. Funds Control Personnel. FCP includes Deputy Commandants,
Commanding Generals, Commanders, Commanding Officers, or
Comptrollers, Deputy Comptrollers, and Budget Officers. Deputy
Commandants, Commanding Generals, Commanders, Commanding Officers
are ultimately responsible for the administrative control of budget
authority issued directly to their commands. Comptrollers, as the 
senior financial managers and advisors within their commands, are 
responsible for command financial management activities, including
administering and enforcing the system of administrative controls
established to prevent ADA violations.  FCP shall be delegated
authority to administratively control funds within the limitations
prescribed under 31 U.S.C. § 1514.
3.A.1.a To establish this authority, the Deputy Commandants,
Commanding Generals, Commanders, Commanding Officers, or Comptrollers
must have a DOA letter from the next higher level of command.
Comptrollers must be formally designated by their respective Deputy
Commandants, Commanding Generals, Commanders, Commanding Officers.
Furthermore, Deputy Comptrollers and Budget Officers can be issued
DOAs from their respective Comptroller. All FCP bear responsibility
for preventing ADA violations.  All Comptroller organization will
track and report personnel and their training status to P&R twice per
year.
3.A.2. Non-Comptroller Personnel. Within an established system of
internal controls, the Commanding Officer or Comptroller may delegate
limited funds-control authority in writing to non-comptroller 
personnel. This authority may include approval of routine 
fund-obligating actions, such as travel, training, supplies, and
purchase card transactions, as well as transaction-level monitoring
of day-to-day funds-control activities.
3.A.2.a. Fund Holders. Fund Holders are typically Supply Officers
assigned to commands without a designated Comptroller. 
(1) Responsibilities: Fund Holders perform limited resource
-management functions on behalf of the Commanding Officer, including
developing phasing plans, establishing funding ceilings, and 
recommending the redistribution of budget authority
(2) Appointment: Only the Commanding Officer may appoint Fund 
Holders.
(3) Documentation: Fund Holders require a formal DOA.
3.A.2.b. Fund Managers. Fund Managers are typically section
representatives delegated limited budget authority to support section
-level requirements.
(1) Responsibilities: Fund Managers may initiate or authorize
execution of routine requirements, including travel, training,
supplies, and similar requirements. They may also recommend the
distribution of funds within the command. 
(2) Appointment: The Commanding Officer or Comptroller may appoint 
Fund Managers.
(3) Documentation: Fund Managers require a standard appointment
letter.
3.A.2.c. Designations and Limitations. Non-comptroller personnel may
be delegated authority to administratively control funds to support
compliance with 31 U.S.C. §§ 1514. However, personnel serving under
this delegated authority are not designated as Fund Control Personnel
and shall not be reported to the Department of the Navy. This
delegation does not confer contracting authority unless the
Contracting Officer explicitly delegates such authority in accordance
with MCO 4400.201.
4. Required training.
4.A. Funds Control for Commanding Officers. Deputy Commandants,
Commanding Generals, Commanders, and Commanding Officers shall
complete the Funds Control for Commanding Officers course within two
weeks of assuming command (reference (e)). Completion of this course
satisfies the initial training requirements for Appropriations Law,
Department of the Navy Budget Execution, and Anti-Deficiency Act
training. Thereafter, while in command, these leaders shall complete
Appropriations Law refresher training at least once every three 
years.
4.A.1.  General Officers and Commanding Officers who
attend Cornerstone at Marine Corps University and complete the 
Appropriations Law training provided by Deputy Commandant, Programs
and Resources representatives are considered to have satisfied the
Funds Control for Commanding Officers course requirement. These 
officers are only required to complete Appropriations Law refresher
training at least once every three years while in command. Commanders
are also strongly encouraged to request a financial management brief
from their Assistant Chief of Staff G-8 or Comptroller, within the
first two weeks of assuming command.
4.B. Appropriations Law Course. Appropriations Law Training. All 
Assistant Chiefs of Staff G-8, Comptrollers, Deputy Comptrollers,
Budget Officers, Funds Holders, and Funds Managers shall complete
initial appropriations law training and refresher training at least
once every three years thereafter (references (a) and (b)). 
Authorized training is available through multiple sources, including
the WarU website and PBISweb. Training content and sources should be
commensurate with the individual's position, responsibilities, and
level of fiscal authority.
4.C. DON Budget Execution Course. All Assistant Chief of Staff G-8,
Comptrollers, Deputy Comptrollers and Budget Officers must complete
the DON Budget Execution Course once in their tenure at the command.
This course provides a broad overview of the DON execution process,
including instruction on the proper issuance and acceptance of 
funding documents. 
4.D. Anti-Deficiency Act (ADA) Training Course. All Assistant Chiefs
of Staff G-8, Comptrollers, Deputy Comptrollers, and Budget Officers
shall complete ADA training annually. Training is available through
authorized sources, including the including the WarU website and PBISweb.
4.E. Non-Compliant FCP.  Any FCP not compliant with the training
requirements will have their delegation of authority to approve
obligating documents suspended or withdrawn until such time as they
are in compliance. This includes personnel who are in the process of
completing the training. 
4.F. Training: Online training for these courses can be found at the
following links:
4.F.1. War Acquisition University (WarU):
https://id.dau.edu/app/dau_virtualcampus_1/exk5bw8t33Hj4e8mo297/sso/
saml (common access card enabled website)
4.F.2. PBISweb: 
https://fmbweb1.nmci.navy.mil/pbis/training/pbisweb_training.cfm
(common access card enabled website)
4.F.3. Third Party Fiscal Law Courses (not a complete list of
options):
4.F.3.A. Practical Comptrollership Course
4.F.3.B. Government Accountability Office (GAO) Principles of 
Appropriations Law Course
4.F.3.C. Department of Agriculture (USDA), Principles of Federal
Appropriations Law Course
4.F.3.D. The Judge Advocate General's Legal Center and School,
Contract and Fiscal Law Department Managed Courses
4.F.3.E. Society of Defense Financial Management (SDFM) Certified
Defense Financial Management (CDFM) Training Course
4.G. The activity comptroller must retain documentation of this
training. 
5. Semi-annual report. Defense Agency Initiative (DAI) L2 
Comptrollers must consolidate and provide the following information,
to include all Tier 1 FCP at all lower levels, to DC, PR (RBD OPS)
semiannually NLT 31 March and 30 September of each year.
5.A. Number of FCP Billets
5 B. Number of FCP Personnel
5.C. Number of FCP in Compliance
5.D. Percentage in Compliance
5.E. If not 100 percent in compliance, provide an explanation why and
confirm that the training will be completed within 2 weeks. 
5.F. All non-compliant FCP will have their delegation of authority
to approve obligating documents suspended or withdrawn until such
time as they are in compliance. 
6. This MARADMIN is applicable to the Marine Corps Total Force.
7. Release authorized by Lieutenant General James B. Wellons, Deputy
Commandant for Programs and Resources.