HomeMy WebLinkAboutMINUTES - 06151999 - C155 TO: BOARD OF SUPERVISORS
FROM: .�. Cod tr
William J. Pollacek, Treasurer-Tax CollectorCosta
� ,.
RATE: June `l 5,'1999 :. County
SUBJECT. AUDIT REPORT ON THE COUNTY TREASURY
SPECIFIC REQUESTM OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATIONdS).
ACCEPT the audit from the County Auditor-Controller on the activities of the County Treasurer and
the Treasury Oversight Committee as required by Government Code Section 27134.
ACCEPT the T'reasurer's response to the above audit.
BACKGRO 1N IREASON(5) FOR RECC}MMENDATIONt }�
Per Government Code Section 27134 and at the request of the Treasury Oversight Committee, the
County Auditor-Controller audited the County Treasury for the period of January 1, 1998, through
December 31: 1993.
The audit and the County Treasurer's response were reviewed at the Treasury Oversight Committee
meeting of May 11, 3999, The County Treasurer and Treasury Oversight Committee members
agreed with the Auditor-Controller's recommendations and Treasurer's responses. Copies of the
Auditor-Controller's audit and the County Treasurer's response are submitted to the Board of
Supervisors for review and acceptance.
JP:CVJ:ceb
Attachments
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ACTION OF BOARD ON June 15 1949
APPROVED AS RECOMPM NOE � OTHER
VOTE OF SUPERVISORS
��4 I HERE13Y CERTIFY THAT THIS IS A TRUE
UNANIMOUS(ABSENT AND CORRECT COPY OF AN ACTION TAKEN
AYES. ALOES: AND ENTERED ON THE MINUTES OF THE BOARD
ASSENT:. ®„ ABSTAIN: OF SUPERVISORS ON THE DATE SI.OwN.
Contact ATTESTED I
QnA
cc: PHIL BATCHELOR,CLERK OF THE BOARD OF
SUPERVISORS AND COUNTY ADMINISTRATOR
By DEPUTY
Office of
COUNTY AUDITOR-CONTROLLER
Contra Costa County
Martinez, California
May 5, 1999
TO; Diane F. Meade, Chairperson, Treasury Oversight Committee
FROM: Kenneth J. Corcoran, Auditor-Controller
Audit Staff. Karen M. Watkins, CIA, Staff Auditor
SUBJECT: Ex4a tination of the Activities of the County Treasurer and the Treasury Oversight
Committee as required by Goverment Code Section 27134
I. SCOPE OF EXAIo rNATION
We have exarnined the activities of the County Treasurer(Treasurer) and the Treasury Oversight
Committee(Committee) as requested by the Committee and as required by Government Code Section
27134. Our examination covered the period of January 1, 1998, through December 31, 1998, and
included such tests and other auditing procedures as we considered necessary to:
1. Determine the extent of compliance with Government Cade Sections 27131 through 27132.4
that govern the establishment, membership and meetings of the Committee.
2. Determine the extent of compliance with Goverment Code Section 27133 that governs the
establishment, review and monitoring of investment policy.
3. Determine the extent to which the quality of the Treasurer's investment portfolio complied
with applicable laws and administrative requirements governing investments, including
Government Code Sections 53601-53607 and 53645 governing authorized investments and
the County's investment Policy.
4. Determine if internal controls were adequate to ensure the safeguarding of the financial assets
ander the Treasurer's control.
5. Determine if the Treasurer has contracted with financial entities for investment services and
safekeeping and restricted investing transactions to brokers and issuers allowed by the
County's Investment Policy.
6. Evaluate the accuracy of the Treasurer's Quarterly Investment Reports.
7. Determine the extent to which investments subject to the Treasurer's control were sold before
maturity,
Diane E. Meade, Chairperson, Treasury Oversight Committee May 5, 1999
Examination of the .Activities of the County Treasurer and the Treasury Oversight
Committee as Required by Government Code Section 27134
II. SUMMARY AND CONCLUSIONS
As a result of our examination, we have concluded that in all material respects;
1. The establishment, membership, meetings and other activities of the Committee were in
compliance with applicable laws.
2. The establishment= review and monitoring of the County's Investment Policy were in
compliance with the law.
3. The quality of the Treasurer's investment portfolio met or exceeded the requirements set forth
in applicable laws and in the County's Investment Policy.
4. Internal controls were adequate to ensure the safeguarding of the financial assets under the
Treasurer's control, except that bank reconciliations need to be more timely and investment
respor4sibilities need to be further segregated (See Sections IIIA & III.E,).
5. The Treasurer has contracted with financial entities for investment services and safekeeping
and has transacted investments with eligible brokers and issuers. The Committee should be
notified when brokers and dealers are used which are not on the Investment Policy's approved
list (See Section III.C.).
b. The Treasurer's Quarterly Investment Report was accurate as of December 31, 199&
7. Our review of investment dispositions subject to the Treasurer's control did not disclose any
that were sold before maturity.
111. FINDINGS AND RECOMMENDATIONS
A. Timely Reconciliation of Bank Account Needed
Condition. In October 1998, the Treasury fell behind in performing the monthly
reconcilations of the Treasurer-Tax Collector's seven bank accounts to the
corresponding checkbooks. Since the December 1998 quarterly cash count, the
Treasury staff has reconciled the six minor bank accounts to the checkbooks.
However, the staff has reconciled the ]Jells Fargo main bank account only through
November 1998, and reports an $11,000 unidentified shortage between the December
1998 Wells Fargo grain bank statement and the checkbook balance. Management
states that the Treasury reconciles daily to the daily bank report. However, the daily
verification only includes the posting of all bank wires, all Automated Clearing House
(ACH) debits and credits, and all deposits greater than or equal to $50,000.
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Diane E, Meade, Chairperson, Treasury Oversight Committee May 5, '1999
Exarnination of the Activities of the County Treasurer and the Treasury Oversight
Committee as Required by Government Code Section 27134
r+
111. FINDINGS AND RECOMMENDATIONS (CONTINUED)
A. Timely Reconciliation of Bank Account Needed (Continued)
Criteria: Timely and complete reconciliation of bank accounts allows detection of
losses or errors. Bank reconciliations are a significant internal control,
Effect: Financial assets could be lost or misappropriated without timely detection.
Delayed detection of bank errors or disputed items may make there more difficult to
,
resolve.
Causes: Management states that they have not had adequate staffing levels during the
past year. The situation has since unproved with the return of an employee from
farmily leave. Also, a full-time investment operations analyst was hired in December
1998.
Management states that the reconciliation has also been delayed by seasonal increases
in deposit volume which take more staff time. The Treasury's volume increases before
the property tax deadlines in December and April. In addition to an increase in deposit
volume, there is an increase in returned checks that the Treasury must process. Also,
during the property tax season, the Treasury may receive tax payments that the bank
credited to Contra Costa County in error. The Treasury staff`must research these
payments, and send therm to the appropriate county.
Recorn mend a tion: Bank, reconciliations are a critical control and should be given
sufficient priority to ensure timely completion. If Treasury staffing is temporarily
reduced, the Department should consider temporarily re-assigning someone in the Tax
Collector's office or hiring a temporary accounting employee.
B. ere ation of Duties Needy Improvement
Condition: There is little segregation of duties for investment transactions in Fund
817740, General County Investment Revenue, Both the Assistant Treasurer and the
Investment Officer evaluate and select the investments available, initiate investment
purchases, prepare the investment tickets that authorize the purchase of an investment,
and prepare Treasury Journals that past the principal and interest to the General Ledger
for their investments. Another employee posts the investment to the internal
investment ledger. The employee who pasts the ledger and the recently-hired analyst
serve as alternates for the Assistant Treasurer and the Investment Officer.
3
Diane E. Meade, Chairperson, Treasury Oversight Committee May 5, 1999
Examination of the Activities of the County Treasurer and the Treasury Oversight
Committee as Required by Government Code Section 27134
III. FINDINGS AND RECOMMENDATIONS (CONTINUED)
B. Segregation of Duties needs Improvement(Continued)
Criteria: Strong internal controls require adequate segregation of duties to detect
errors and help prevent misappropriations. Good business practices include a
minimum level of segregation between initiation, authorization, and posting functions.
Effect: The risk of loss through undetected error or misappropriation is increased.
Cause: Management states that the Treasury has not had the staffing level necessary to
fully segregate duties. On a given day, either the Assistant Treasurer or the Investment
Officer may not be available.
Recommendation: When both are available, if the Assistant Treasurer or the
Investment Officer initiates an investment, the other should approve it. This should be
documented by signature or initials on the investment ticket. When one is absent, one
of the alternates should review and approve the investments made. With the hiring of
the new investment operations analyst, the Treasury should segregate the recording of
investments from the Initiation and authorization of investments.
C. Treasury Should Notify Committee When_Us n N pproved Brokers and Dealers
Condition: The Investment Policy's list of approved brokers and dealers includes a
provision that allows the Treasury to make purchases of investments from brokers and
dealers that are not on the list, if needed. Three of the eight purchases reviewed had
brokers or dealers that were not on the list of approved brokers and dealers.
Criteria: The Treasury Oversight Committee should know which brokers and dealers
the Treasury uses to effectively monitor its investment activities.
Effect. The Committee may not have sufficient information about brokers and dealers
used by the"Treasury.
Cause: The Treasury needs some flexibility to accommodate changes in needs and
iilk vendors during the year covered by the Investment Policy.
4
Diane E. Meade, Chairperson, Treasury Oversight Committee May 5, 1999
Examination of the Activities of the County Treasurer and the Treasury Oversight
Committee as Required by Government Cade Section 27134
j
III. FINDINGS ANIS RECOMMENDATIONS (CONTINUED) j"
C. Treasury Should Notify Committee When Using Non-Approved Brokers and Dealers
(Continued)
Recommendation: The T reasury Oversight Committee should consider an
amendment to the Investment Policy that requires the Treasury to notify the
Coral-nittee when brokers and dealers are used which are not on the Investment Policy's
approved list. The Treasury could include this information to its quarterly investment
report.
IV. STATUS OF PRIOR AUDIT RECOMMENDATIONS
RECOMMENDATION STATUS
1997. The Treasurer should seek to amend This recommendation was implemented.
the County's Investment Policy to include Dropped.
L.A,1 . investments and other legal
investments the Treasurer deems
appropriate.
1997. The Treasurer sho=uld submit This recommendation was implemented.
nominations for all future Committee Dropped.
membership changes to the Board for
appointment.
1997. The Treasurer should seek to amend The Treasurer amended the policy to require five
the County's Investment Policy to include days notice and pending sale or maturity of the
criteria for the withdrawal of funds by any investment. This should provide sufficient lead
agency including an assessment of the effect time for the Treasury to accommodate
of the withdrawal on the remaining withdrawals, Drop recommendation.
investments in the County Treasury.
1997. The Treasurer should correct these This recommendation was implemented. No
postings to properly state investment exceptions were found. Drop recommendation.
categories and continue the review of daily
postings to detect such misclassifications in
the future.
5
Diane E. Meade, Chairperson, Treasury Oversight Committee May 5, 1999
Examination of the Activities of the County Treasurer and the Treasury Oversight
Committee as Required by Government Code Section 27134
IV, STATUS OF PRIOR AUDIT RECOMMENDATIONS-(CONTINUED)
RECOMMENDATION STATUS
1997. The County's Investment Policy This recommendation was implemented.
should be revised to specify the distribution Dropped.
of the Treasurer's Quarterly Investment
Report to the Committee and any other
required distributions, citing the appropriate
Government Codes.
We would like to express our appreciation to the Treasury staff, especially Clarissa Javier, Beverly
Rellar and Janette San Luis for their assistance and cooperation during this audit.
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CONTRA COSTA COUNTY
TREASURER-TAX COLLECTOR
625 COURT STREET, ROOM 100
MARTINEZ, CA 94553-0063
DATE: May 10, 1999
TO: Diane E. Meade, Chairperson, Treasury OversightGorrirruittee,
FROM: William J. Pollacek, Treasurer-Tax Collector
SUBJECT: RESPONSE TO EXAMINATION OF ACTI eES OF THE COUNTY
TREASURER BY THE COUNTY AUDITOR-CONTROLLER DATED
MAY 5, 1999
----------
The following is the Treasurer's response to Section III of the Auditor's Findings and
Recommendations:
A. TimgyReconciliation of Bank Account Needed
As of May 10, 1999, the Wells Fargo Bank statements have been reconciled
through the month of February, 1999. The March, 1999, reconciliation is in
progress.
In the Wells Fargo Bank statement for the month of December, 1999, the $11,000
difference was composed of four items. Two items were listed as cleared items in
the 'Treasurer's reconciling work sheets but were not per the bank statement. Two
other uncleared items were not listed on the Treasurer's reconciling work sheets.
December is an unusually heavy banking month due primarily to the first
installment of property taxes.
With the advent of"paperless" banking, one Treasury staff person has been
assigned to review, analyze and reconcile all fed wires and automated
clearinghouse activities (A.C.H.) for the past several years. used on the
December, 19988 banking transactions, these two large components make up over
83% of the month's total entries. The total entries were composed of$1 a I I billion
in credits and $1.12 billion in debits. The 83% for December converts to $929
million in debits and another $929 million in credits in fed wires and A.C.H.'s.
These are reconciled within 48 hours or less. Also, all other entries $50,000 or
more are reconciled within 48 hours or less. The remaining entries are reconciled
when the bank statements are received.
Diane E. Meade, Chairperson, Treasury Oversight Committee
May 10, 1999
Page 2
Through the years the Treasury has prided itself on complete reconciliation of its
records. An estimated 9510 of entries are reconciled within 48 hours.
Since December, a Treasury Operations Analyst was hired and an Accounting
Technician returned from maternity leave.
B. Segregation of Duties Needs Improvement
The recommendation to have two different staff members initiate and approve
investments was implemented effective May 6, 1999. A new investment form is in
place. The form has a specific box for the second authorized signature and
approval (see Exhibit A). The completion of this box is an intrinsic part of the
Treasurer's documentation.,
Additionally, if the investment is for a district, the primary authorization is a letter of
instruction from the district's authorized personnel. This procedure has always
been in place for directed investments.
Journals are prepared primarily by either the Investment Officer or the Investment
Operations Analyst, or by other available authorized staff as necessary. The
prepared journals are then verified for completeness and accuracy by authorized
staff, other than the preparer. This segregates the recording process. Two
signatures or initials are on the journal (see Exhibit B).
C. Trea§gaS,hould Notify-Committee When Using Non-Approved Brokers and
Dealers
The list of Brokers and Issuers has been updated and revised to include all the
entities with whom the Treasury is currently doing business (see Exhibit C). This
vein replace page 20 of the Investment Policy of February, 1999.
In the future the Quarterly Report will include information on any new investment
relationships. It will be noted on page 3, which lists other notes (see Exhibit D).
CVJ:ceb
Attachments
cc: Clarissa V. Javier, Assistant Treasurer
a:auditresponse599.dem
too disk
CONTRA COSTA CC)UN7YINV"ESTMENT TRANSAC770JV MATUpjTy Exhibit A
nUDEDATF-- =rLZMENTDAMr
3771:
i FUND NO. NAME
AMOUNT MONEY MAX CONTAC
.&WES fEN'r RPO CP CIS I CUSIP
TYPE RIA NCD GOVT OTHER C`ERrNo DTD
.SECURITY DESCRIP270N.
MATUPI'TY: NO.OF DAYS-
*RATE:
COUPON: PRICE:
FOR 1N f RESP" SEARING CRY�ELia:
CJS= YIELD number €car lMAK instead of rate
E
PAR VALUE DATE OF LAST COUPON !NT'ERE.ST DUE.
PRINCIPAi, COUPON DATES QUARTERLY
DISCOUNT SEW-At 1AL
ACCRUED�' i�A1'Ct£tII'Y
"TOTAL.NET
BRC KEM- CON'TACT- �
S TTLEta INT THRU: HILD BY: NO TIFTED: Tom:
.SPECIAL LNSTRUCIIONS:
rNTER.EST. DATE RECEIVED AMOUNT DP NO. BIDS
SALE
E'LJR
516/,%l 0: ts`c ket599.wk3
Exhibit a
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Exhibit C
BROKERS AND ISSUERS
ABN AMRO, Incorporated John Deere Capital Corporation
American Express Credit Corporation J. P. Morgan Securities Incorporated
Associates Corporation of North America Lehman Brothers, Incorporated
Associates First Capital Mechanics Bark
Bank of America Mellon Bark
Bank of the Vest Merrill Lynch
Bankers Frust Company Merrill Lynch Government Securities,
Barclays Capital, Incorporated Incorporated
Bear Stearns & Company, Incorporated Morgan Stanley Dean Witter
California Arbitrage Management Program Morgan Stanley & Company, Incorporated
Chase Securities, Incorporated NationsSanc Corporation
Citibank NationsSanc Montgomery Securities LLC
Civic Sank of Commerce Norwest Banks
Credit Suisse First Boston Norwest Investment Services
Deere & Company PaineWebber, Incorporated
Donaldson, Lufkin & Jenrette securities Prudential Securities, Incorporated
Corporation Public Financial Management,
First Commercial Sank Incorporated
Ford Motor Credit Company Rauscher Pierce Refsnes, Incorporated
General Electric Capital Corporation Salomon Smith Barney, Incorporated
General E=lectric Capital Services Sumitomo Sank of California
General Electric Company Union Sank
Gilford Securities, Incorporated Washington Mutual
Glendale Federal Sank Wells Fargo Sank
Goldman, Sachs & Company Westamerica Sank
Government Perspectives
Mote: The County Treasury will not be limited to the above list. Others will be included as long as all
conditions for authorized brokers and dealers set forth in this policy are ret. Additionally, deletions and
additions are based on the maintenance of required credit quality as rated by Standard and Poor's,
Moody"s, GF1 (Gerry Findley Incorporated) and other recognized rating services and reliable financial
sources.
20
Exhibit D
NOTES TO INVESTMENT PORTFOLIO SUMMARY AS OF MARCH 31, 1999
1. All report information is unaudited but due diligence was utilized in Its preparation.
2. There may be slight differences between the portfolio summary page and the attached
exhibits and statements for investments managed by outside contractors or trustees. The
variance is due to the timing difference in recording transactions accomplished by
contracted parties during interim periods and later transmitted to the appropriate county
agency and/or the Treasurer's Office. In general, the Treasurer's records reflect booked
costs at the beginning of a period.
kNotes
3