A2513 DEPOSITORY BANK ACCOUNTS - RED LINE 7-8-19.DOCX
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MARICOPA COUNTY INTERNAL POLICY Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Issue Date: DEPOSITORY BANK ACCOUNTS Policy Number: 6/20/12 Current Adoption Date: Current Implementation Date: Approved By: Policy Category: Finance Maricopa Revision County Board of No: N/A Initiating Department: Department of Supervisors and FinanceApproved by: Special Revision BOARD OF SUPERVISORS DistrictsBoard Date: N/A Agenda Number: Original Adoption June 2012 Date: A.I. PURPOSE The purpose of the Maricopa County policy for Treasurer Depository Accounts is to To establish procedures and provide guidelines to guidance for County Departments/Special Districts, for on the appropriate usage and reconciliation of Treasurer’s Office (Treasurer) established Depository Bank Accounts. II. AUTHORITY Arizona Revised Statutes (A.R.S.) § 11-491 authorizes the County Treasurer to keep all money belonging to the County. A.R.S. § 11-492 directs all County Departments/ to submit public monies to the County Treasurer. III. APPLICATION This Policy applies to all Maricopa County elected and appointed departments as well as the Flood Control District of Maricopa County, the Maricopa County Library District, and the Maricopa County Stadium District (Special Districts). The Board of Supervisors is authorized to jointly adopt policies applying to the Special Districts will be guided in establishing internal controls to help ensure adequate segregation of duties for cash handling, recording, and reconciling Depository Account under the Intergovernmental Agreement, C-06-18-393- 6-00, approved on April 11, 2018. Page 1 of 7 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: IV. DEFINITIONS A. Accounting String: Specific accounting codes used by the County’s financial accounting system to identify, process and post transactions to the proper fund, department, unit, agency, activity, and revenue and/or expense object codes. Department/Special District directors and administrators are responsible for ensuring that personnel are aware of and comply with the requirements of this policy. B. DEFINITIONS B. Agency Web: County Treasurer’s portal which facilitates the revenue processing cycle and allows users to view Fund account balances, activity and various month-end reports. Departments upload CRTs directly to this website. C. Bank Statement – a Depository Account: A statement produced by the County’s servicing bank ofwhich lists all financial transactions occurring in the Depository Bank Account over a period of time, generally aone calendar month. D. Cash Receipt Transmittal (Cash Receipt - CR) – County’s – CRT): An internal processCounty document utilized by Departments to record theand post Depository Bank Account transactions indirectly to the accounting ledgers (Treasurer’s and County-wide Financial Accounting systems).accounting system and simultaneously to the County’s financial accounting system. The Treasurer posts Cash Receipts as Treasurer’s Receipts (TR) inCRT is uploaded directly to the Treasurer’s ledgers. accounting system while a nightly interface creates a draft of the identical transaction in the County’s financial accounting system. E. Department – An administrative subdivision of Maricopa County. Examples are : For the purpose of this policy, “Department” refers to any division of Finance, Office of the Legal Defender, etc. the County, including elected and judicial branch offices and Special Districts. Depository Bank Account (Depository Account) – a): A bank account established for the benefit of a specific Department by the Treasurer atwith the County’s servicing bank which allows for deposits of public monies by County Departments/Special Districts. An account is established for the benefit of a specific Department/Special District. A Depository Account utilizes two separate general ledger accounts on the Treasurer’s system. The account allows for Page 72 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: depository transactions only, without the ability to disburse money or issue checks. Deductions from a Depository Account, other than the Departments. While operational transfers done(also known as “sweeps”) are performed periodically by the Treasurer, are considered exceptions and are limited to returned dishonored checks, charges/fees generated by the servicing bank, and preauthorized credit card fees/disputed chargeback transactions. Fund – a fiscal and accounting entity with a self-balancing set of accounts segregated for the purpose of carrying out specific activities or obtaining certain objectives in accordance with regulations, restrictions, or limitations. F. Special District – an administrative and political subdivision of Maricopa County that has a Board of Directors and an independent taxingDepartments have no disbursement or withdrawal authority, i.e., Flood Control District of Maricopa County, Maricopa County Library District and Maricopa County Stadium District. with this type of account. G. Treasurer’s Bank Ledger Account (Bank Ledger Account) – an account): One of two accounts on the Treasurer’s general ledger (e.g., 10-X25-XXX115XXX-100-XXXX) that records the Depository Account transactions directly from the bank. A summary of transactions areis electronically remitted to the Treasurer by the servicing bank on a daily which are immediatelybasis and recorded to the Bank Ledger Account with an offsetting entry to the Clearing Account (defined below). TheAs this occurs via an electronic interface, the Bank Ledger Account ismust always be in agreement with the servicing bank balance. H. Treasurer’s Clearing Account (Clearing Account) – a pass-through account): One of two accounts on the Treasurer’s general ledger (e.g., 30-025-XXX210100-100-1000- XXXX-XXXXX) that facilitates the recording of Depository Account depository account transactions from the servicing bank to the County’s account ledgers (on both the Treasurer’s and County-wide Financial Accountingthe County’s financial accounting systems). Money isAmounts are transferred fromout of the Clearing Account ledger and posted to the identified County Fund(s) using a Cash Receiptdepartment-created CRT submitted to and processed by the Treasurer. I. Treasurer’s GeneralAgency Fund Ledger Report (Treasurer GL Report) – a monthDetail Reports: Month-end reportreports produced by the Treasurer reporting all Page 73 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: posted transactions for all accounts onmaintained by their accounting system, including the Bank Ledger Account and Clearing Account. The report isreports are available at https://treasurer.maricopa.gov/agency/ for to authorized users. at https://treasurer.maricopa.gov/AgencyWeb. C. USAGE V. POLICY A. County Departments/Special Districts are able to conduct necessary deposit transactions through the Treasurer’s cashiering collection window. Certain Departments/Special Districts experiencing a financial or operational burden whenin making deposits atdirectly with the Treasurer’s Office may be approved for a Depository Account atrequest approval to open a depository account with the County’s servicing bank in order to facilitate deposits. In general, Depository Accounts allow for convenience and efficiencies to both the County and others (e.g., citizens, taxpayers, governments).the deposit process. B. Once approved, Depository Accounts are The County Treasurer is responsible for establishing new depository accounts. Requests for new depository accounts must receive prior approval from the Department of Finance and the Treasurer’s Office and must be established bywith the TreasurerCounty’s servicing bank. C. Departments are required to justify the need for a depository account both when requesting a new account and on an ongoing basis, once the account is established. Additionally, Departments must fulfill their fiduciary responsibility with the use of the account as the account is to be used primarily for facilitation of various Department/Special District accounting revenue processing. D. The Director (or designee) of each Department is responsible for establishing and adhering to internal controls that ensure adequate security and segregation of duties for cash handling, recording, and reconciling the depository account transactions. E. Departments are only allowed to make deposit transactions which. Departments are not granted check issuance or other disbursement authority. The servicing bank is allowed to make deductions from a depository account for returned/dishonored checks, deposit corrections, credit card processor fees and chargeback transactions. Allowable Department deposit transactions include, but are not limited to, deposits of: : Page 74 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: 1)1. Cash and checks received for payment of services, fines, fees, etc., 2)2. Credit card settlements for payment of services, fines, fees, etc., and 3)3. Electronic payments received as reimbursements or advancementsadvances from various governments (Federal, State, and Local Governments) for grants and for payment of services, fines, fees, etc., provided by the County. F. Deposit transactions to a Depository Account can only be made by the following methods: 1)1. In person at the Treasurer’s Office, 2)2. In person at the County’s servicing bank, 3)3. Via an armored car delivery to the County’s servicing bank, 4)4. Via an electronic Image Direct Deposit (IDD) check reader, 5)5. Via an electronic direct deposit made by Automated Clearing House (ACH) or wire transfer, and 6)6. Via a lockbox service established at the servicing bank for mailed in payments. G. The use ofDepartments are encouraged to request electronic payment methods and/or automated equipment, such as ACH, wire transfers, credit cards, IDD check readers, ATMs and kiosks, which allow for less check/cash handling by employees, stronger internal controls, and timely receipting of deposits. D. RECORDING TRANSACTIONS Page 75 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: H. Recording revenues or expenditures To effectively record revenue transactions in the proper accounting period is only achieved with timely and accurate submission of Cash Receipts. A Cash Receipt records the financial transaction in the County’s accounting ledgers (Treasurer’s and County-wide Financial Accounting systems). Departments/Special Districts must prepare a Cash Receipt for all Depository Account transactions. , Departments must record their depository transactions in a timely and accurate manner in both the Treasurer’s and County’s financial systems. Transactions not processed within the same month of the deposit date at the bank will result in timing differences on the month-end reconciliation. I. Depository clearing accounts must be reconciled by an employee whose job duties are independent of cash handling or recording functions within 30 days of month-end close. All reconciliations and supporting documentation must be retained in accordance with record retention policies. J. Fiscal year-end reconciliations for June activity must be submitted to the County Treasurer and the Department of Finance within 45 days of year-end close. K. The depository account is subject to external auditor review and/or read only electronic access at any time by the Department of Finance, Internal Audit, and the Budget Office. L. Failure to comply with all requirements listed herein shall result in the closure of the Department’s depository bank account. VI. RECORDING TRANSACTIONS A. Departments must upload a Cash Receipts Transmittal form (CRT) formatted as a .csv file to the Treasurer’s accounting system (Agency Web) for all depository account transactions in order to ensure revenues and/or expenditures are recorded in the proper accounting period and to the proper fund. B. Delays in submitting Cash Receipts result in a loss of earnings to the depositing Fund as the monies remain in the Depository Account until a Cash Receipt is processed by the Treasurer. Delays also addCRTs may result in difficulty toperforming account reconciliations and research. as well as a loss of interest income to the depositing fund. C. Departments collecting receipts directly should deposit amounts at the bank daily, and should timely upload the corresponding CRTs. Documentation for all CRT uploads, at a minimum, should include the following information depending on the type of transaction: Page 76 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 DEPOSITORY BANK ACCOUNTS Accounts Policy Issue Date: Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: Deposits collected by Departments/Special Districts should be deposited and remitted daily, if significant, or at least weekly to the : date, accounting template number, complete Treasurer. Cash Receipts should indicate the following: 1)1. Deposits – date, accounting string, such as applicable fund, Department/Special District, agency, revenue object code, approved Treasurer’s source code, and amount deposited., preparer and approver names (required to be two different Department or County personnel). 2) Deposit adjustments or deductions (e.g., returned dishonored checks , bank charges, and/or credit card chargebacks) –invoice fees): date, accounting template number, complete Treasurer accounting string, such as applicable fund, Department/Special District, agency, revenue object code, approved Treasurer’s source code, and adjustment amount indicated in parenthesis “($X.XX)”. 3)2. Deductions (e.g., bank charges and/or fees and credit card fees only) – date, accounting string, such as applicable fund, Department/Special District, agency, expenditure object code, and deductedwith a minus sign in front of the amount indicated in parenthesis “($X.XX)”.“-X.XX” and preparer and approver names (required to be two different Department or County personnel). D. Other adjustments and corrections, such as those for monies deposited to the wrong Treasurer’s fund/account, should be communicated to the Treasurer (Accounting Division) for necessary journal entries to the County’s accounting ledgers. processed as a journal entry (JV) in the financial accounting system, which will automatically update the Treasurer’s accounting system during the nightly interface process. reconciliations Specifically, the Treasurer’s process to record Depository Account transactions is as follows: 1) A bank account transaction summary is electronically transmitted by the servicing bank to the Treasurer’s Office daily. 2) Summary information is then recorded on the Treasurer’s system to the Bank Ledger Account (10-X25-XXX) with the offset to the Clearing Account (30-025- XXX). 3) Treasurer’s Office personnel process Cash Receipts prepared by Departments/Special Districts to clear transactions out of the Clearing Account into Page 77 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 DEPOSITORY BANK ACCOUNTS Accounts Policy Issue Date: Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: the indicated Fund on the Treasurer’s system. A stamped copy of the processed Cash Receipt is forwarded to the Department of Finance where the transaction is entered into the County-wide Financial Accounting system. 4) For investment purposes determined by the Treasurer Investment Officer, cash transfers (i.e., sweeps) are taken from the Bank Ledger Account and moved to the Treasurer servicing account. No Department/Special District action is needed for these transactions. E. RECONCILIATIONS VII. FOR REPORTING AND INTERNAL CONTROL PURPOSES, DEPOSITORY ACCOUNTS MUST BE RECONCILED MONTHLY TO THE TREASURER’S Departments must obtain the month-end general ledger reports for the Treasurer’s clearing account corresponding to each depository account in order to reconcile the account balances within 30 days of month-end close by an employee whose job duties are independent of cash handling and recording functions. Properly preparing and posting Cash Receipts will result in the Treasurer’s Clearing Account maintaining a zero ($0.00) balance. Bank statements and the Treasurer’s Bank Ledger Account activity must always agree. A. A properly completed reconciliation on a monthly basis. The reconciling process will identify missing or incorrect postingpostings of Cash Receiptsdeposits, unrecorded charges/fees (i.e., deductions), bank errors, departmental input errors and deposits in transit, and Department/Special District/bank errors. Immediate corrective steps must be taken if needed. . Daily cash receipts should be reconciled to total cash collections (IDD, cash register, credit card, lockbox, etc.). The daily cashiering function and reconciliation between cash received and cash register sales reports are not addressed in this policy. The Depository Account reconciliation process requires examination of two accounts. 1) Bank Ledger Account (10-X25-XXX) - all transactions posting to the servicing bank account will be netted and downloaded electronically to the Treasurer’s Bank Ledger Account. The ending balances from the month-end bank statement and balances on the Treasurer’s GL Report should agree. If the balances do not agree, the situation must be immediately researched and reported to the Treasurer to determine corrective action. Page 78 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 DEPOSITORY BANK ACCOUNTS Accounts Policy Issue Date: Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: 2) Clearing Account (30-025-XXX) – the Treasurer’s Clearing Account is critical to and needs the most attention in the reconciliation process. The account is designed to be a pass through account for all transactions to be cleared by a Cash Receipt ultimately resulting in a zero ($0.00) balance. Cash Receipts must be processed for any transactions remaining in this account (excluding timing differences) during the reconciliation process. The ending balance on the Treasurer’s GL Report, minus deposits without Cash Receipts, plus deposit adjustments (e.g., dishonored checks) and deductions (e.g., charges/fees) without Cash Receipts, plus or minus bank/Department/Special District errors should equal zero ($0.00). Identified differences must be investigated and resolved as soon as possible, preferably by end of the month so as not to impact another month but at minimum within 30 days. See Exhibit A for a reconciliation example and recommended procedures. F. GUIDELINES Departments/Special Districts with Depository Accounts must adhere to the following: 1) Departments/Special Districts must justify the need to establish a Depository Account through the Department of Finance. 2) The account can only be established by authorized account signers in the Treasurer’s Office upon approval from the Treasurer’s Accounting Division Manager. Designated Department/Special District appointees are users of the account. 3) Only deposit transactions are allowed. Check issuance or disbursements are prohibited. 4) The only deductions allowed are those made by the servicing bank for their fees and returned/dishonored checks or by credit card processors for fees and chargeback transactions. 5) Departments/Special Districts must prepare and submit Cash Receipts to properly record all Depository Account transactions in the County’s accounting ledgers (Treasurer’s and County-wide Financial Accounting systems) within 15 days from month-end. Page 79 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: 6) Depository Accounts must be reconciled by an employee whose job duties are independent of cash handling or recording functions within 30 days of month-end close. 7) Fiscal year-end reconciliations for June activity must be submitted to the Treasurer (Accounting Division) and Department of Finance within 60 days of year-end close. 8) All reconciliations, including back-up support must be retained in accordance with record retention policies. Records are subject to review upon request by any Department/Special District listed in bullet point (10) below. 9) Closure of the Treasurer’s Depository Account may occur if Departments/Special Districts do not: 1. Properly perform Month-end general ledger reports are also known as “Agency Fund Ledger Detail” reports and are located on Agency Web. 2. CRTs should be prepared and uploaded to Agency Web in a timely manner with accurate information to ensure the Treasurer’s Clearing Account (210100-100-1000- XXX-XXXX) maintains a zero ($0.00) balance. 3. Interest income is not earned on monies which remain in the clearing account until a CRT is submitted to transfer the monies to the proper Fund. B. Banking transactions are transmitted electronically by the servicing bank to the Treasurer and recorded to two (2) separate ledger accounts in the Treasurer’s system. Therefore, Departments must reconcile the following two accounts in the Treasurer’s general ledger: 1. Bank Ledger Account (115XXX-100-XXXX) – Under normal circumstances, the month- end servicing bank statement balance and the ending balance on the Treasurer’s Agency Fund Ledger Detail report should be in agreement. If there is a discrepancy, the situation must be researched immediately and corrective action taken. In these instances, Departments should notify the Treasurer’s office immediately. 2. Clearing Account (210100-100-1000-XXX-XXXX) – The Treasurer’s clearing account is designed to be a pass-through account only. All transactions are cleared (i.e, zeroed out) when the Department uploads a CRT in .csv format directly to Agency Web for each depository account transaction occurring during the month. a. A balance in the clearing account at month-end indicates that there are transactions remaining for which no corresponding CRT has been uploaded or processed at month-end. With the exception of timing differences, only a CRT upload will resolve the discrepancy and bring the balance to zero. The most common reconciling items consist of the following: Page 710 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 DEPOSITORY BANK ACCOUNTS Accounts Policy Issue Date: Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: i. Deposits without a CRT (i.e., unprocessed by the Treasurer and therefore, not posted in the Financial accounting system). ii. Deposit adjustments (i.e., dishonored checks, errors etc.) without CRTs. iii. Bank deductions (i.e., charges/fees) without CRTs. iv. Bank/department errors (i.e. keying errors). a. For further clarification on reconciliation procedures, see the Depository Account Reconcilationreconciliations as required by this policy, b. Prepare Cash Receipts for all transactions, c. Record the financial transaction in the accounting ledgers, d. Have a continuing need for the account, or e. Fulfill their fiduciary responsibility with the use and financial activity of the account. Closure of Depository Accounts will result in Departments/Special Districts being restricted to cash basis only operations, eliminating credit card acceptance. As these limitations may significantly affect business operations of a Department/Special District, the Treasurer in conjunction with the Department of Finance, will work with the Department/Special District to address any issues. If issues are not remedied within a prescribed period, actions will be taken to close the account. The Department of Finance and Treasurer will notify the County Manager of any action to close a Depository Account. 10) The account is subject to external auditor review and/or read-only electronic access at any time by the Department of Finance, Internal Audit Department, and Office of Management and Budget. G. REFERENCE AND ADDITIONAL RESOURCES Uniform Accounting Manual for Arizona Counties (UAMAC) – provides internal controls for accounting and financial reporting by Arizona counties, in conformity with statutory requirements and generally accepted accounting principles. The UAMAC is published by the Auditor General. It can be found at http://www.azauditor.gov. Department of Finance Recommended Procedures for Dishonored Checks – provides guidance for handling dishonored checks. The procedure can be foundspecific Page 711 of 712 Maricopa County Title: Number: Internal Policy Title: Depository A2513 Accounts Policy Issue Date: DEPOSITORY BANK ACCOUNTS Number: 6/20/12 Policy Category: Finance Initiating Revision Department: No: N/A Department of Revision FinanceCurrent Date: N/A Adoption Date: information, detailed procedures and document examples. The manual is located at https://mymc.maricopa.gov/202/Procedures-and-Manuals. Department of Finance Image Direct Deposit (IDD) Recommended Procedures – provides guidance for processing checks electronically using IDD machines. The procedure can be found at https://mymc.maricopa.gov/202/Procedures-and-Manuals. C. https://mymc.maricopa.gov/205/Cash-Management. The Depository Account Reconciliation Example –Manual is for reference only and not considered part of the policy. The Reconciliation ExampleIt may be periodically updated without Board of Supervisor approval. Refer to Exhibit A attached. , as deemed necessary, to accommodate the effective administration of this policy. Agenda Numbers: C-18-12-044-6-00; C-18-12-045-6-00; C18-12-046-6-00; C-18-12-047-6-00 Revision History Page 712 of 712 Version Revision Date Description of Revision 1 06-20-2012 Initial version. (C-18-12-044-6-00) 2 Minor edits to make terminology more consistent, updated references to the County financial system, and updated policy template