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MARICOPA COUNTY SHERIFF'S OFFICE Memorandum
To: Joy Rich, County Manager From: James Prindiville
Shelby Scharbach, Assistant Manager Chief Financial ff er
John Lewis, Finance Director MCSO
Royce Flora, Treasurer
Subject: Request for Establishing an Administrative Bank Date: January 24, 2019
Account
Attached is the packet requesting the establishment of Administrative Bank Account for the Marieopa County
Sheriff's Office.
This account is necessary to comply with banking regulations. The existing Custodial/Trust account for the inmate's
monies usually has a large balance ($1M plus at times), and a separate Administrative bank account should be
established and funded by MCSO in order to limit the amount accessible to the third-party provider (NUMI). NUMI
Financial would only have access to this newly established Administrative bank account for the reimbursement of the
funds loaded on the debit cards thereby limiting MCSO's exposure to fraud (or errors).
Revised: 12.21.17
MARICOPA COUNTY SHERIFF'S OFFICE
PAUL PENZONE
SHERIFF
Maricopa County Policy #A2504 — Establishing Administrative Bank Accounts.
Request for Establishing an Administrative Bank Account
Background:
NUMI Financial (NUMI) is the card issuer for all Maricopa County Sheriff's Office (MCSO) release cards.
MSCO went "cashless" in the jail facilities and implemented the NUMI release card system in March
2015. Approximately one hundred (100) release cards are issued daily, seven days a week. At the time
of release, the inmate is provided a pre-loaded debit card with the amount of money remaining on the
inmate's account. This debit card is issued by NUMI Financial and must be ready for immediate use by
the recently released inmate. Currently, MCSO initiates a daily ACH transfer to reimburse NUMI for the
previous days' releases; however this process can take several days due to weekends, holidays, etc. Due
to recent changes in NUMI's reimbursement criteria, an additional MCSO administrative bank account is
necessary to facilitate the funding of the debit cards.
Request:
MCSO is requesting the establishment of a separate Custodial/Trust Account to allow for NUMI Financial
to initiate ACH reimbursements for the previous days' pre-loaded debit cards issued. The requested
Administrative bank account will be established with the County's servicing bank.
Justification:
The existing Custodial/Trust account for the inmate's monies usually has a large balance ($IM plus at
times), and a separate Administrative bank account should be established and funded by MCSO in order
to limit the amount accessible to the third-party provider (NUN). NUMI Financial would only have
access to this newly established Administrative bank account for the reimbursement of the funds loaded
on the debit cards thereby limiting MCSO's exposure to fraud (or errors).
Allowing NUMI Financial to initiate the ACH reimbursement will help them to remain in compliance with
banking regulations and will allow this time saving process to continue.
550 W Jackson Street • Phoenix, Arizona 85003
(602) 876-1000 • Statewide Toll Free 1-800-352-4553 • WWW.MCSO.ORG
Attachment A
REQUEST FOR ADMINISTRATIVE BANK ACCOUNT
Department Name: Maricopa County Sheriff's Office Low Org# 5001 Date 12/17/18
Account Contact Name: Richard Saathoff Phone: 602-876-4623
Description of why an Administrative Bank Account is needed:
MCSO is requesting the establishment of separate Custodial/Trust Account to allow for NUMI Financial
to initiate ACH reimbursements for the previous days' pre-loaded debit cards provided to the recently
released inmate.
Type of Administrative Bank Account being requested (based on the definitions on Section II.A) and
reason the account type is needed:
Custodial/Trust Account for Electronic Funds Transfer (EFT) Account.
To limit MCSO's exposure to fraud (or errors) by granting access to an account with a very limited cash
balances by an outside vendor.
Name of Ma ricopa County/Special District Employees to be authorized signers (minimum of 2 required):
1. Cal Davidson 3. Sara Bagley
2. Suzanne Baier 4. Jackie Santor
Name of Maricopa County/Special District Employee to act as Custodian:
Richard Saathoff Marcella Ranus
Type of Account Requested: Anticipated Account Activity
Checking Account X Number of Deposits per Month 25
Savings Account Average Monthly Deposit 187,000.00
Investment Account Number of Withdrawals per month 30
Interest Bea ring (Y/N) Average Monthly Withdrawal $ 187,000.00
Explanation of Source of Funds (e.g., fines, fees, charges for services, bonds,
restitution/wards/inmates/probationers monies held in trust, etc.):
The account will initially be funded by MSCO with a transfer of $50,000 from the existing Inmate Trust
Account and thereafter, on a daily basis (excluding weekends and holidays) by the amount of the
previous days' releases and the amount loaded to the pre-paid debit cards.
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank
Accounts Issue Date: May 2000
Policy Category: Finance Approved By: Maricopa Revision No: 2
County Board of Supervisors
Initiating Department: and Special Districts Revision Date: June 20, 2012
Department of Finance
PURPOSE
To establish the procedures, maintenance and reporting requirements for all
Maricopa County/Special District Administrative Bank Accounts. This Policy does
not apply to any account established under A.R.S. § 12-286 or the Minimum
Accounting Standards (MAS) as established by Arizona Administrative offices of the
Courts ("AOC").
II. DEFINITIONS
A. Administrative Bank Account: A County bank account established,
separately from the central servicing and Depository Bank accounts, but
pursuant to the County's banking services agreement unless excepted, to
which funds may be deposited or from which funds may be drawn, including,
but not limited to, the following:
1. Administrative Processing Account: A bank account used for the
facilitation of processing payment functions such as payroll clearing and
direct deposit functions.
2. Bond Covenant Account: A trust bank account established pursuant to the
bond agreements.
3. Custodial Account: A bank account maintaining funds held temporarily by
Maricopa County in its fiduciary capacity for individuals or governments,
which are distributed per statute, court order or at the owner's request.
4. Electronic Funds Transfer (EFT) Account: A bank account established
pursuant to vendor and/or servicing bank requirements for processing
electronic payments via Automated Clearing House (ACH) or wire.
5. Escrow Account: A bank account maintaining funds held in escrow such
as for the purchase of real property pursuant to title company
requirements.
6. Third-Party Administrative Account: A bank account maintaining funds
held in trust for Maricopa County employees such as for payment of their ,
worker's compensation and health care related expenses.
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
7. Trust Account: A bank account maintaining funds held in trust by Maricopa
County for individuals or governments as required by statute such as
Public Fiduciary ward accounts.
B. Depository Bank Account: A County bank account established pursuant to
Maricopa County Policy A2513.
C. Maricopa County: All Maricopa County departments, elected offices, the
Maricopa County Superior Court and the Clerk of the Court.
D. Public Monies (for purposes of this Policy only): All public funds, arising from
any source, or accruing under the provisions of law to Maricopa County
and/or Special Districts, and any funds held by Maricopa County/Special
Districts in trust for non-Maricopa County/Special District entities or in a
fiduciary capacity.
E. Special Districts: The Maricopa County Library District, Flood Control District
and Stadium District.
Ill. PROCEDURES
A. Maricopa County and Special Districts shall submit all Public Monies to the
County Treasurer ("Treasurer"). Arizona Revised Statutes (A.R.S.) § 11-492.
B. All Public Monies shall be deposited into the Maricopa County central servicing
bank managed by the Treasurer except as outlined herein. See A.R.S. §§ 11-
251(11); 492; 493; 604.01. In certain instances, it is necessary for bank
accounts, separate from the central servicing bank accounts, to be established
(the "Administrative Bank Accounts"). It is Maricopa County's and the Special
District's desire that these Administrative Bank Accounts be interest-bearing
whenever possible.
C. This Policy does not include any bank account holding funds not meeting the
description of Public Monies. Bank accounts set up for the benefit and operation
of an employee sponsored committee, association, organization, club, etc. must
be established using a non-affiliated Maricopa County/Special District name and
Taxpayer Identification Number (TIN). It is strictly prohibited to establish such
non-Public Monies accounts using Maricopa County/Special District names and
using the County's Taxpayer Identification Number (TIN).
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Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
D. Establishing an Administrative Bank Account:
1. Administrative Bank Accounts shall be the exception. All
departments/Special Districts seeking an Administrative Bank Account
must request approval from the Maricopa County Board of
Supervisors/Special District Board of Directors as outlined below. All
Administrative Bank Accounts must be established at the Maricopa
County Servicing Bank where practicable. Additionally, all Administrative
Bank Accounts must be opened as a Maricopa County/Special District
account. Any exceptions must be approved by the Board of
Supervisors/Special District Board of Directors. Any bank account opened
with Public Monies that does not comply with this policy is in violation of
this policy and may be considered a misappropriation of funds. Such
account will be closed immediately and Maricopa County/Special Districts
will report any such violation to the County Attorney or Attorney General
as appropriate.
2. All requests for an Administrative Bank Account shall be submitted first to
the County Manager, or designee(s), by completing the "Request for
Administrative Bank Account" form (see Attachment A) and a memo,
where needed, outlining the following:
a. the operational need that cannot be met under the County's/Special
District's current banking/warrant issuing procedures;
b. affirmation that the account is consistent with legal, operating, reporting
and internal control requirements of the County/Special District;
c. acknowledgment that the account must, unless an exception is
awarded, be established at a branch of the County's servicing bank;
and,
d. statutory authority for the creation of the account, where applicable;
and,
e. a list of servicing bank branch locations to be used by the
department/Special District;
f. a list of persons to act as signers and/or custodians on the account,
including job title; and
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Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
g. if an exception is sought, the name of the preferred bank to hold the
account.
3. If approved by the County Manager, or designee(s), and the County
Treasurer, the County Manager, or designee, shall recommend approval
of the account to the Board of Supervisors/Special District Board of
Directors in open meeting. If approved, a copy of the Board-approved
"Request for Administrative Bank Account" form will be returned to the
requesting department/Special District. The Clerk of the Board shall
maintain the original form. The County Manager, or designee(s), shall
maintain a copy of the Board-approved form and a record of all
Administrative Bank Accounts. This record will include the
department/Special District name, account number, account type, purpose
of account, account custodian, and authorized signers. County Manager,
or his designee(s) will transmit this information to the Treasurer's office for
record keeping.
4. Once approval is received from the Board, the department/Special District
must:
a. work with the Department of Finance ("Finance") to establish the new
account with the Maricopa County Servicing Bank where possible;
b. ensure that the new account is opened as a Maricopa County/Special
District account using the County's TIN, where applicable;
c. ensure that the Finance and the Treasurer have electronic access to
the new account;
d. ensure that the authorized signers and custodians listed on the new
account paperwork with the bank corresponds to those identified on
the "Request for Administrative Bank Account" form;
e. work with Finance and the Treasurer to ensure that the appropriate
cash handling procedures are used to manage the bank account; and
f. comply will all reporting requirements as outlined herein.
E. Guidelines and Maintenance of an Administrative Bank Account;
1. All changes to authorized signers or the custodian must be authorized by
County Manager and the Treasurer, or designee(s) (see Attachment C).
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Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
2. The Departments of Finance, Internal Audit, Management and Budget,
and Treasurer are authorized to view the account detail, electronic and/or
hard copy back-up data, for any Administrative Bank Account at any time.
3. The County Manager, or designee(s), is authorized to review the
justification for the Administrative Bank Account at any time and request
additional information regarding the account and activity as needed.
4. If the County Manager, or designee(s), deems any Administrative Bank
Account "unnecessary", the County Manager, or designee(s), shall
present the recommendation to close the account to the Board of
Supervisors/Special District Board of Directors for a vote. If the Board of
Supervisors/Special District Board of Directors votes to close the
Administrative Bank Account, it shall be closed as expeditiously as
possible. The closure of such accounts shall be overseen by Finance.
5. Dishonored checks - The department/Special District will adopt
appropriate procedures for handling checks, received as payments, which
are later returned unpaid by the bank because of nonsufficient funds
(NSF), stop payment, closed account, etc. At a minimum, the
department/Special District should: reverse the deposit from the account,
set up a separate ledger/list of dishonored checks, and adopt the best
practices outlined within the Maricopa County Department of Finance
Recommended Procedures for Dishonored Checks.
6. No lines of credit or overdraft agreements may be established for any
Administrative Bank Account. There should be sufficient funds in the
account to cover checks issued at all times. Overspending and carrying
deficit cash balances in any Administrative Bank Account is strictly
prohibited.
7. All bank deposits must be collateralized by at least 101% of the deposits
not covered by depository insurance as required by ARS §35-323 G and
the Maricopa County Deposit and Investment Risk Disclosures Policy
(A2509).
8. Expenditure disbursements made from Administrative Bank Accounts,
maintaining Public Monies, must follow authorization, procurement code
and competitive bid procedures established by A.R.S., County policies,
and/or applicable grant agreements; where required by law. A.R.S. §§ 41-
2512; 11-254.01. See also Maricopa County Procurement Code.
5
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
9. Any and all expenditure disbursements made from Administrative Bank
Accounts must be for approved transactions or invoices and have two
authorization approval signatures. No advances or loans may be paid
from Administrative Bank Accounts unless specifically approved by policy.
Advancement transactions related to active or potential criminal matters
by law enforcement agencies are permitted.
10. For Administrative Bank Accounts reported on the County's financial
system (Advantage) via a Fund and Balance Sheet Account, transaction
activity, such as deposits and disbursements, must be recorded at least
monthly on the County's financial system at the activity and object code
level using explanatory transaction descriptions.
11. Independent contractor payments - The department/Special District will
adopt appropriate procedures, in accordance with applicable IRS codes
and regulations, for the reporting of payments made from Administrative
Bank Accounts to independent contractors for services provided (i.e.,
Form 1099).
12. Payments to employees for wages or reimbursement costs should be
made through the County's payroll system and not using checks, or other
forms of disbursements, from Administrative Bank Accounts.
13. The department/Special District will adopt appropriate internal controls
regarding cash receipts and cash disbursements. At a minimum, the
department/Special District should separate the following major duties and
functions among different employees:
a. Cash receipts:
1) cash handling — mail should be opened by employees with no
responsibility for maintaining accounting records; checks, warrants,
drafts or money orders must immediately be stamped "for deposit
only"; cash receipts should be deposited daily, if significant, or at least
every week; maintain validated deposit slips for each bank deposit;
2) recordkeeping;
3) reconciling bank accounts;
b. Cash disbursements:
1) approving cash disbursements;
2) preparing checks;
3) distributing checks; and
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,
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
4) maintaining accounting records.
For additional resources, the 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.
F. Monthly Reporting - The Custodian of the account must maintain bank
reconciliations and perform such reconciliation monthly. All reconciliations,
including back-up support for all receipts and disbursements from the account,
must be retained in accordance with record retention policies. These records are
to be subject to review upon request by any department listed in Section 111
Authorized signers shall not perform any bank reconciliation or any other
bookkeeping function. At least one authorized signer must review and approve
the bank reconciliation on a form similar to Attachment B. Failure to comply with
this section will result in the closure of the Administrative Bank Account.
G. Annual Reports - The applicable year-end forms, detail of accounts, and bank
reconciliations must be submitted to Finance as required in the fiscal year-end
closing package.
IV. EXEMPTION
A. Accounts established pursuant to a court order, for bond covenants, escrows, or
compliance with federal and/or state law that name a Maricopa County
department, Special District or elected office to manage the account, and
Stadium District accounts that have been established in accordance with the
Related Use Agreements as defined in the Facility Use Agreement are exempt
from all parts of this policy, except for the requirements of Section 111.D.
Agenda Numbers: C-49-12-097-6-00; C-49-12-098-6-00; C-49-12-099-6-00;
C-49-12-100-6-00
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,
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
Attachment A
REQUEST FOR ADMINISTRATIVE BANK ACCOUNT
Department Name Low Org # Date
Account Contact Name Phone Number
Description of why an Administrative Bank Account is needed:
Type of Administrative Bank Account being requested (based on the definitions in
Section II.A) and reason the account type is needed:
Name of Maricopa County/Special District Employees to be authorized signers
(minimum of 2 required):
Name of Maricopa County/Special District Employee to act as Custodian:
Type of Account Requested: Anticipated Account Activity:
Checking Account Number of Deposits per Month
Savings Account Average Monthly Deposit $
Investment Account Number of Withdrawals/Checks per Month
Interest Bearing (YIN) Average Monthly Withdrawals/Checks $
Explanation of Source of Funds (e.g., fines, fees, charges for services, bonds,
restitution/wards/inmates/probationers monies held in trust, etc.):
8
Maricopa County Title: Establishing Number: A2504
Internal Policy Administrative Bank Issue Date: May 2000
Accounts
Policy Category: Finance Initiating Department: Revision No: 2
Department of Finance Revision Date: June 20, 2012
For Department of Finance Use Only
Financial reporting of deposits & investments held in Administrative Bank Account
Fund classification:
Special Revenue[ ] Debt Service[ ] Capital Project[ ] Enterprise[ ]
Internal Service[ ] Agency[ ]
Advantage Fund Number (N/A for Agency Funds)
Balance Sheet Account 0006/0013 (N/A for Agency Funds)
See attached Memo for additional information.
REQUIRED APPROVALS
Department or Office Approval
Appointing Authority Approval Date
Completed by County Manager (or designees)
County Manager Approval Date F2-nv,h?
County Treasurer Approval Date i/ 779
Completed by Clerk of the Board of Supervisors/Board of Directors
Date of Board of Supervisors/Directors Approval Agenda #
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