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MARICOPA COUNTY INTERNAL POLICY Policy Number: A2504 Policy Title: Current Adoption 02-13-2019 ADMINISTRATIVE BANK ACCOUNTS Date: Current 02-13-2019 Implementation Date: Approved by: Board Agenda C-18-19-004-6-00 Number: BOARD OF SUPERVISORS Original Adoption Date: 05-2000 I. PURPOSE To establish the procedures and guidance for all Departments on the appropriate usage, maintenance, and reconciliation of Administrative Bank Accounts. II. AUTHORITY Arizona Revised Statutes (A.R.S.) § 35-301 which outlines the duties and liabilities of custodians of public monies. III. APPLICATION This Policy applies to all Maricopa County 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 under the Intergovernmental Agreement, C-06-18-393-6-00, approved on April 11, 2018. This policy also applies to employees of County elected and judicial branch offices unless the elected official has implemented a similar policy specific to his or her office This Policy does not apply to any account established: under A.R.S. § 12-286 for the Clerk of the Superior Court; the Minimum Accounting Standards (MAS) as established by Arizona Administrative offices of the Courts; or Stadium District accounts that have been established in accordance with the Related Use Agreements as defined in the Facility Use Agreement, except for the requirements of Section V., item B. Also, the Policy does not include any bank accounts holding funds not meeting the description of Public Monies. Bank accounts setup for the benefit and operation of an employee sponsored committee, association, organization, or club must be established using a non-affiliated Department name and Taxpayer Identification Number. IV. DEFINITIONS A. Administrative Bank Account: A County bank account established with the County’s servicing bank, but separate from the Treasurer’s central servicing and Depository Bank accounts. Under extenuating circumstances, it is possible to establish an administrative account outside of the County servicing bank (for example, if a branch is not conveniently located nearby). Funds may be deposited and/or withdrawn from an Administrative bank account. The following is a representative, though not exhaustive, sampling of certain types of administrative accounts: 1. Bond Covenant Account A trust bank account established pursuant to the bond agreements. Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 2. Custodial Account A bank account maintaining funds held temporarily by the County in its fiduciary capacity for individuals or governments, which are distributed per statute, court order or at the owner’s request. 3. Escrow Account A bank account maintaining funds held in escrow, such as for the purchase of real property pursuant to title company requirements. 4. Processing Account – A bank account used to facilitate the processing of payment functions such as payroll clearing and direct deposit functions. 5. Third-Party Administrative Account A bank account maintaining funds held in trust for County employees such as for payment of their worker’s compensation and healthcare- related expenses. 6. Trust Account - A bank account maintaining funds held in trust by the County for individuals or governments as required by State statute B. Appointing Authority: An elected official, the single administrative or executive head of a Department, or the designated representative authorized to act in this capacity. C. Department – For the purpose of this Policy, “Department” refers to any division of the County including elected and judicial branch offices, and Special Districts. D. Depository Bank Account: A County bank account established pursuant to Maricopa County Policy A2513. E. 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. V. POLICY A. It is the County’s policy to ensure all Public Monies are deposited into the County’s central servicing bank account and managed by the Treasurer. In certain instances, it may be necessary to establish separate bank accounts to facilitate certain required administrative procedures. These bank accounts will herein be referred to as “Administrative Bank Accounts” and shall have the following requirements: 1. All Departments seeking to establish an Administrative Bank Account must request approval from the County Board of Supervisors and/or Special District Board of Directors. 2. Administrative Bank Accounts shall be interest-bearing whenever possible and must be established at the Treasurer’s Servicing Bank where practicable. Additionally, the accounts must be opened in the name of the Department using the County’s tax identification number (TIN). Any exceptions must be approved by the Board of Supervisors/Special District Board of Directors. 3. Expenditure disbursements made from Administrative Bank Accounts must follow proper 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- 2501; 11-254.01. See also Maricopa County Procurement Code. Page 2 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 4. Any bank account opened with Public Monies that does not comply with this policy is in violation of this policy which may be considered a misappropriation of funds. Such account will be closed immediately and any such violation shall be reported to the County Attorney or Attorney General as appropriate. B. 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: 1. The operational need that cannot be met under the Department’s current banking/warrant issuing procedures; 2. Affirmation that the account is consistent with legal, operating, reporting and internal control requirements of the County; 3. Acknowledgment that the account must, unless an exception is granted, be established at a branch of the County’s servicing bank. If an exception is sought, the name of the preferred bank to hold the account must be disclosed; 4. Statutory authority for the creation of the account, where applicable; and, 5. A list of persons to act as signers and/or custodians on the account, including job title. C. The County Manager’s or designee(s)’ recommendation of approval shall be forwarded to the Board of Supervisors and/or Special District Board of Directors in open meeting. Upon Board approval, the “Request for Administrative Bank Account” form will be returned to the requesting Department for further processing. D. 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 name, account number, account type, purpose of account, account custodian, and authorized signers. County Manager or designee(s) will transmit this information to the Treasurer for record keeping. E. The following activity is strictly prohibited within Administrative Bank Accounts: 1. Payments to employees for wages or reimbursement costs - these payments should be made through the County’s payroll system or other approved method. 2. Establishing lines of credit or overdraft agreements 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. 3. Making loan payments or processing advances from Administrative Bank Accounts unless specifically approved by policy. Advancement transactions related to active or potential criminal matters by law enforcement agencies are permitted, however. F. Upon final Board approval, it is the responsibility of the Department to: 1. Work with the Department of Finance (“Finance”) to establish the new account with the Treasurer’s Servicing Bank whenever possible and ensure the new account is opened in the name of the County Department using the County’s TIN; 2. Ensure Finance, Internal Audit, Budget, and the Treasurer are authorized to view the account detail, electronic and/or hard copy back-up data, for any Administrative Bank Account at any time. Page 3 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 3. Ensure that the authorized signers and custodians listed on the bank’s new account paperwork agrees to the information provided on the “Request for Administrative Bank Account” form; all changes to authorized signers or the custodian must be authorized by the County Manager and the Treasurer, or designee(s) (see Attachment C ). 4. Work with Finance and the Treasurer to ensure that the appropriate internal controls regarding cash handling procedures are used to manage the bank account. At a minimum, the Department should separate the following major duties and functions among different employees: a. Cash handling – checks, warrants, drafts or money orders received 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; b. Recordkeeping (i.e. posting transactions); c. Reconciling bank accounts; d. Approving cash disbursements; and e. Preparing checks. 5. Adopt appropriate procedures for handling dishonored checks received but later returned unpaid by the bank because of nonsufficient funds (NSF), stop payment, closed account, etc. At a minimum, the Department should reverse the deposit from the account, set up a separate ledger/list of dishonored checks, and adopt the best practices outlined within Finance’s Recommended Procedures for Dishonored Checks. 6. 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). G. If the account is maintained in the Financial (Accounting) System as a balance sheet account, the Department must process a journal voucher to record all transaction activity (i.e., deposits and disbursements) on the County’s financial system. Proper accounting string information is required. H. A monthly bank reconciliation must be performed with 30 days of month end. 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 subject to review upon request by any department listed under item F. 2. Authorized signers shall not perform any bank reconciliation or any other record keeping function. At least one authorized signer must review and approve the bank reconciliation on a form similar to Attachment B. I. 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. J. Failure to comply will all requirements listed herein shall result in the closure of the Department’s Administrative Bank Account. Page 4 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 Attachment A REQUEST FOR ADMINISTRATIVE BANK ACCOUNT Department Name Fund # Date Account Contact Name Phone Description of why an Administrative Bank Account is needed: Type of Administrative Bank Account being requested (based on the definitions in Section IV.B) 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 (Y/N) 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.): Page 5 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 For Department of Finance Use Only Financial reporting of deposits & investments held in Administrative Bank Account Fund classification: See Special Revenue [ ] Debt Service [ ] Capital Project [ ] Enterprise [ ] Internal Service [ ] Agency [ ] Advantage Fund Number (N/A for Agency Funds): Balance Sheet Account 1006/1013 (N/A for Agency Funds) 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 ______________ Completed by County Treasurer County Treasurer Approval _____________________________ Date ______________ Completed by Clerk of the Board of Supervisors/Board of Directors Date of Board of Supervisors/Directors Approval _________ Agenda # _____________ Page 6 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 Attachment B I hereby certify that all the activity and transactions reported above for this bank account are: 1) for a valid public purpose; and 2) done in accordance and compliance with applicable authorization, purchasing, procurement, and competitive bid guidelines and procedures established by A.R.S. and County policies. Furthermore, I certify that monies are available for payment for such transactions, and that if the available monies are from a federal grant, contract, or trust agreement, these transactions and purchases are authorized under the terms of such grant, contract, or trust agreement. By_____________________ ____________ Authorized Signer Signature Date The above bank reconciliation example was obtained from the June 2008 Uniform Accounting Manual for Arizona Counties (UAMAC) published by the State of Arizona Office of the Auditor General. Page 7 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 Attachment C NOTICE OF CHANGE TO THE CUSTODIAN OR AUTHORIZED SIGNER OF AN ADMINISTRATIVE BANK ACCOUNT DATE: TO: County Manager (or his designees) FROM: <Custodian or Authorized Signer> <Department Name> SUBJECT: Notice of Change to the Custodian or Authorized Signer of the Following Administrative Bank Account: <Banking Institution Name, Account Name and Number This request is to notify the County Manager of the following change in custodian or authorized signer for the above-indicated Administrative Bank Account: New Authorized Signer or Custodian: Previous Authorized Signer or Custodian: <Name> <Name> <Title> <Title> <Work location address> <Work location address> <Work phone number> <Work phone number> __________________________ _________________________________ Signature Signature REQUIRED APPROVALS Department or Office Approval Appointing Authority Approval ____________________________ Date ____________ Completed by County Manager (or designees) Approval _____________________________________________ Date ____________ Page 8 of 9 Policy Title: Policy Number: A2504 ADMINISTRATIVE BANK ACCOUNTS Current Adoption Date: 02-13-2019 Revision History Version Revision Date Description of Revision 1 05/2000 Initial version. County Manager adopted. 2 05/26/2010 Rescinds and supersedes the previous A2504 and requires departments and elected offices to submit new requests for approval for each current account to the County Manager by June 28, 2010. (C-06-10-475-6-00, C-06-10-476- 6-00, C-06-10-477-6-00, and C-20-10-049-6-00) 3 06/20/2012 Review and update language. Establish administrative bank accounts for HR, Payroll, and Employee Records. (C-49-12-097-6-00, C-49-12-098-6-00, C- 49-12-099-6-00, and C-49-12-100-6-00) 4 02/13/2019 Review, update language, cite authority. Update to current policy formatting. (C-18-19-004-6-00) Page 9 of 9