AUDIT OF CASH REGISTER, IMPREST FUNDS, AND PETTY CASH TRANSACTIONS JULY 01, 2004 THROUGH JUNE 30, 2005 TABLE OF CONTENTS

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3 AUDIT OF CASH REGISTER, IMPREST FUNDS, AND PETTY CASH TRANSACTIONS JULY 01, 2004 THROUGH JUNE 30, 2005 TABLE OF CONTENTS INTRODUCTION... 1 SCOPE AND OBJECTIVES... 2 METHODOLOGY... 3 SUMMARY OF AUDIT FINDINGS... 4 POLICE DEPARTMENT... 4 TRANSFER OF CUSTODIAN FORMS WERE NOT COMPLETED... 4 DOCUMENTS SUPPORTING IMPREST FUND ADVANCE PURCHASES WERE NOT PROVIDED TO CUSTODIANS IN A TIMELY MANNER OTHER CONTROL DEFICIENCIES RELATIVE TO THE HANDLING OF IMPREST /PETTY CASH FUNDS SAFEGUARDING OF CASH COLLECTIONS FINANCE DEPARTMENT... 6 LACK OF DOCUMENTATION OF SUPERVISORY VERIFICATION OF CASH REGISTER VOIDS. 6 PARKS AND RECREATION DEPARTMENT VIRGINIA KEY BEACH... 7 LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS... 7 CONFERENCES, CONVENTIONS, AND PUBLIC FACILITIES DEPARTMENT.. 8 LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS... 8 FINDINGS AND RECOMMENDATIONS POLICE DEPARTMENT TRANSFER OF CUSTODIAN FORMS WERE NOT COMPLETED DOCUMENTS SUPPORTING IMPREST FUND ADVANCE PURCHASES WERE NOT PROVIDED TO CUSTODIANS IN A TIMELY MANNER OTHER CONTROL DEFICIENCIES RELATIVE TO THE HANDLING OF IMPREST /PETTY CASH FUNDS SAFEGUARDING OF CASH COLLECTIONS FINANCE DEPARTMENT LACK OF DOCUMENTATION OF SUPERVISORY VERIFICATION OF CASH REGISTER VOIDS PARKS AND RECREATION DEPARTMENT VIRGINIA KEY BEACH... 19

4 LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS CONFERENCES, CONVENTIONS, AND PUBLIC FACILITIES DEPARTMENT 21 LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS... 21

5 INTRODUCTION Management has established petty/change and imprest funds Citywide for the purpose of making change, and for the procurement of small and non-recurring expenditures relating to official City business transactions. The City collects various types of revenues in the form of cash or cash equivalents, which are assessed and processed through automated cash register machines located in various departments Citywide. Cash is the standard medium of exchange in our society and therefore is a very liquid and desirable asset. The liquidity and desirability of cash makes it inherently risky to safeguard against theft and/or misappropriation. The request for a new petty cash, imprest, change fund or closure of an existing fund, notification of a custodian change, and increase or decrease in the amount of a fund are processed in the Finance Department. The petty cash, imprest, or change fund custodian is responsible for all transactions relating to the fund, including safekeeping of the fund, obtaining proper documentation for expenditures, and preparing requests for reimbursement. To determine compliance with the applicable policies and procedures, we performed surprise petty cash and imprest cash audit for 11 petty cash and imprest fund totaling $73,050. The amount of the petty cash and imprest fund accounts audited constitute 81% of the 79 funds totaling $89,925. We also reviewed cash register machine transactions in the Finance, Police, Parks & Recreation, and Conference, Conventions and Public Facilities departments to ensure that selected transactions were properly processed, reconciled, and recorded on financial statements. 1

6 SCOPE AND OBJECTIVES The proper administration of public funds requires management to establish and maintain internal control policies and procedures that would provide reasonable assurance that specific objectives/responsibilities would be achieved. As part of its oversight responsibilities, the Office of the Independent Auditor General (OIAG) performs operational audits to determine the extent to which management achieved those objectives. The audit focused primarily on surprise imprest/petty cash fund verifications and examination of cash register transactions. The verification/examination covered the period June 1, 2005 through August 31, In general, the audit focused on the following broad objectives: To examine whether petty cash/change and imprest fund transactions were executed in accordance with all applicable policies, procedures, and management directives. To examine whether cash or cash equivalents processed through automated cash register machines were properly executed, reconciled, and recorded in the City s financial statements. To determine whether cash and checks collected were deposited into the City s bank account in a timely manner. To perform surprise counts of petty cash, change and imprest fund balances. To verify petty cash and imprest fund balances. Other audit procedures as deemed necessary. 2

7 METHODOLOGY We conducted our audit in accordance with generally accepted government auditing standards issued by the Comptroller General of the United States. The audit methodology included the following: Obtained sufficient understanding of the internal control Policies and procedures and determined the nature, timing and extent of substantive test of details necessary and performed the required tests. Determined compliance with all the objectives noted on page 2. 3

8 SUMMARY OF AUDIT FINDINGS POLICE DEPARTMENT TRANSFERS OF CUSTODIAN FORMS WERE NOT COMPLETED. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that when the custodian of a working fund is transferred to another employee, the employee releasing said funds should obtain a receipt for same, and the employee who received the funds should sign for the receipt. Said policies/procedures require such transfer to be documented on a Transfer of Custodian Form and filed with the Finance department. However, our review disclosed that 2 employees in 2 Sections of the Police departments who handled $20,000 of imprest funds were not the custodians of record. DOCUMENTS SUPPORTING IMPREST FUND ADVANCE PURCHASES WERE NOT PROVIDED TO CUSTODIANS IN A TIMELY MANNER. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that documentation relating to purchases paid with petty cash, including any unused cash advance, shall be submitted to the custodian within five business days from the receipt of the advance. However, our review disclosed that documentation relative to imprest fund advance purchases totaling $9, were not submitted to the custodian in a timely manner as noted on page 12. The timely accounting for imprest fund advances would enhance accountability and ensure proper use and processing of imprest funds and related transactions. OTHER CONTROL DEFICIENCIES RELATIVE TO THE HANDLING OF IMPREST /PETTY CASH FUNDS. The availability of a petty cash/imprest fund ensures that purchases of non-major items and/or essential services are procured on expedited basis. Cash is a liquid asset and is easily susceptible to misappropriation, if not properly safeguarded. Therefore, preventive controls are necessary to 4

9 properly safeguard cash from possible theft and/or misappropriation. Our review disclosed that imprest fund monies totaling $ were used to pay for membership renewal fees and cellular telephone services contrary to the Police department s procedures; several imprest fund monies were commingled; and imprest fund overage totaling $ was disbursed to an employee. SAFEGUARDING OF CASH COLLECTIONS. The Police department processed and collected approximately $1.08 million in revenues through cash register transactions during the audit period. The revenues collected include alarm, storage, towing, off-duty surcharge, permit, and other administrative fees. Cash collections are secured in automated cash register machines located in the Records, Special Events, and Property Units. Cash is the standard medium of exchange in our society and therefore is a very liquid and desirable asset. The liquidity and desirability of cash makes it inherently risky to safeguard against theft and/or misappropriation. Our review disclosed that accesses to the cash registers were not restricted to one employee during each of the shift and there was no formal turnover of the cash contained in the cash register machine at the end of each shift; and cash collections were not processed and provided to the City s armored courier contractor for bank deposit within 24 hours after being signed for by the Vault Section of the Property Unit. 5

10 FINANCE DEPARTMENT LACK OF DOCUMENTATION OF SUPERVISORY VERIFICATION OF CASH REGISTER VOIDS. The Treasury Section of the Finance department processed and collected approximately $106 million in revenues through two cash registers located on the fourth floor of the Miami River Center (MRC) building during the audit period. During each day various types of fees were collected by each cashier. Our review of 39 cash register tapes for the month of November 2004 disclosed a total of 32 voids that resulted from wrong cash register ring-up of various sales transactions. The supervisory pre-approval of the voids/no-sales transactions that were processed as part of the tapes tested were not documented. The absence of supervisory review and documentation of such review increases the risk of irregularities and/or misappropriations. Subsequent to our audit inquiry, supervisory review is now being documented. 6

11 PARKS AND RECREATION DEPARTMENT VIRGINIA KEY BEACH LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS. The Virginia Key Beach processed and collected approximately $54,000 in toll booth revenues during the audit period. A toll charge of $10 is waived and not assessed on Solid Waste, Miami-Dade Water and Sewer and similar trucks/vehicles seeking access to the Beach on a daily basis. Our review disclosed that Cashiers were not required to obtain and document information relating to vehicles that were granted free access and there is no electronic device at the toll booth entrance that could independently track the number and/or type of vehicles that gain access to the Beach; the two employees who handled change funds were not the custodians of record; and cash collections were not deposited into the City s bank account within 24-hours after receipt, as required. 7

12 CONFERENCES, CONVENTIONS, AND PUBLIC FACILITIES DEPARTMENT LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS. The Conferences, Conventions, and Public Facilities department is responsible for managing all City owned marinas (vessel docking facilities). As part of our audit we reviewed safeguards relative to cash collections at Miamirina at Bayside and Marine Stadium Marina. The Miamirina at Bayside processed and collected approximately $1.4 million in docking fees during the audit period and the Marine Stadium Marina processed and collected approximately $891,000 in docking fees during said audit period. Our review disclosed the following control deficiencies: MIAMIRINA AT BAYSIDE. Our review of the transactions log for the $50 change fund, disclosed 105 different days (May 6, 2005 through August 20, 2005) of shortages ranging from $6.47 to $ Our review disclosed that employees who handled the petty cash and change funds, in the amounts of $150 and $155 respectively, were not the custodians of record. As first reported in audit report number , dated July 18, 2000, we again observed that dock attendants secure the fees collected in their individual pockets. When monies collected are secured in employee s pockets, there is increased risk that errors, fraud, and/or irregularities could occur and not be detected in a timely manner. City s policies and procedures for working, petty cash and change funds provide that request for reimbursement of any expenditure from petty cash should be made at least once each month. However, as of August 19, 2005 audit field work date; the petty cash fund disbursements totaling $54.68 for the months of June through August, 2005 were not submitted for reimbursement as required. 8

13 MARINE STADIUM MARINA. A review of the transactions log for the $150 change fund, disclosed a shortage of $5.05. Also, a review of the transactions log for the $300 petty cash fund disclosed an overage of $3.35. Upon review of the transactions and cash balance relative to a $300 petty cash fund, we observed an un-cashed reimbursement check for $33.30 dated September 28, We also noted that the remaining cash balance available for emergency needs totaled only $ Petty cash transactions log indicated that the fund had not been replenished since January 11, Our review disclosed that employees who handled the petty cash and change funds, in the amounts of $300 and $150 respectively, were not the custodians of record. 9

14 FINDINGS AND RECOMMENDATIONS POLICE DEPARTMENT TRANSFERS OF CUSTODIAN FORMS WERE NOT COMPLETED. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that when the custodian of a working fund is transferred to another employee, the employee releasing said funds should obtain a receipt for same, and the employee who received the funds should sign for the receipt. Said policies/procedures require such transfer to be documented on a Transfer of Custodian Form and filed with the Finance department. However, our review disclosed that 2 employees in 2 Sections of the Police departments who executed imprest fund financial transactions through the use of credit union debit cards were not the official designated custodians of record as indicated on the Finance department s official records: Custodian Imprest Fund Section Changed Amount Criminal Investigation Yes 10, Internal Affairs Yes 10, Total $ 20, Also, documentation relative to imprest fund advance purchases were not submitted to the custodian in a timely manner as noted on page 12 and 13. Upon audit inquiry, we were informed that the high ranking Officers (fund custodians) listed on the Finance department s custodianship official form are accountable for all transactions and under their respective supervisions other investigators (fund users) are designated to execute financial transactions. We noted that the names of the investigators are included as authorized users on each of the credit union imprest accounts. However, to enhance accountability and also ensure that all policies and procedures relative to the use of the imprest fund monies are adhered to, the names of all fund users should be included on the custodianship official forms. 10

15 Recommendation: To enhance accountability and also ensure that all policies and procedures relative to the use of the imprest fund monies are adhered to, we recommend that the names of all fund users be included on the custodianship official forms. Auditee s Response and Action Plan The auditee concurred with the findings. See written responses on pages 25 through

16 DOCUMENTS SUPPORTING IMPREST FUND ADVANCE PURCHASES WERE NOT PROVIDED TO CUSTODIANS IN A TIMELY MANNER. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that documentation relating to purchases paid with petty cash, including any unused cash advance, shall be submitted to the custodian within five business days from the receipt of the advance. However, our review disclosed that documentation relative to imprest fund advance purchases were not submitted to the custodian in a timely manner as noted below: Imprest Fund Date Cash Document supporting Imprest Fund Advance Advance Expenditures Section Amount Received was Received were provided on Internal Affairs $ 10,000 $ / /16/05 Criminal Investigation 10,000 1, / /13/05 Criminal Investigation 3, / /11/05 Crime Supression Unit 8,000 1, / Was not provided as July 12, 2005 Crime Supression Unit 2, / /8/05 Total $ 28,000 $ 9, The custodian of the fund is accountable for all aspects of the disbursements, record keeping, safeguarding, and reimbursement for any shortages of the funds. Therefore, the timely accounting for imprest fund advances would enhance accountability and ensure the proper use and processing of imprest funds and related transactions. Recommendation We recommend that that documentation relating to purchases paid with petty cash, including any unused cash advance, shall be submitted to the custodian within five business days from the receipt of the advance, as required. 12

17 Auditee s Response and Action Plan The auditee concurred with the findings and recommendation. See written responses on pages 25 through

18 OTHER CONTROL DEFICIENCIES RELATIVE TO THE HANDLING OF IMPREST /PETTY CASH FUNDS. The availability of a petty cash/imprest fund ensures that purchases of non-major items and/or essential services are procured on expedited basis. Cash is a liquid asset and is easily susceptible to misappropriation, if not properly safeguarded. Therefore, preventive controls are necessary to properly safeguard cash from possible theft and/or misappropriation. Our review disclosed the following deficiencies: On March 1, 2003, $152 of criminal investigation imprest fund monies was disbursed for National Court Reporters Association membership renewal fees, contrary to the provisions of Section (f) of the Police department s policies and procedures manual, which prohibit such use. Also, we noted that $ of Internal Affair s imprest fund monies was used to pay for cellular telephone services, contrary to Section (b) of the Police department s policies and procedures manual. Monetary transactions relative to criminal investigation imprest fund monies as reflected on imprest fund journal indicated that several imprest fund monies were commingled in connection with various activities. We noted that three transfers totaling $5,000 were made from one imprest fund to another. Said transfers were subsequently replenished. The commingling of imprest funds increases the risks of errors and/or irregularities. Upon reconciling available cash with supporting receipts for the Compliance Task Force imprest fund, we noted that said fund had an overage totaling $ The imprest fund records indicated that on June 28, 2005, the overage was disbursed to an employee who (not the custodian of record) handled and/or processed all disbursement transactions from the imprest fund. We were informed that the amount was disbursed to the employee because prior to the establishment of the imprest fund, said employee used his personal funds to pay for certain task force related transactions. Therefore, any resulting overage belonged to the employee. 14

19 Recommendation We recommend that the appropriate internal control procedures be implemented to address each of the deficiencies noted above. Auditee s Response and Action Plan The auditee concurred with the findings and recommendation. See written responses on pages 25 through

20 SAFEGUARDING OF CASH COLLECTIONS. The Police department processed and collected approximately $1.08 million in revenues through cash register transactions during the audit period. The revenues collected include alarm, storage, towing, off-duty surcharge, permit, and other administrative fees. Cash collections are secured in automated cash register machines located in the Records, Special Events, and Property Units. Cash is the standard medium of exchange in our society and therefore is a very liquid and desirable asset. The liquidity and desirability of cash makes it inherently risky to safeguard against theft and/or misappropriation. Our review disclosed the following internal control deficiencies: The Automated cash registers used in the Records, Alarm, Property, and Special Units can be accessed by several employees within each unit through the use of personal identification numbers. For example, in the Property Unit there are up to 5 employees in each of the 3 different shifts. We noted that accesses to the cash registers are not restricted to any employee during each of the shift and there is no formal turnover of the cash contained in the cash register machine at the end of each shift. Under these conditions, there is increased risk that errors, and/or irregularities could occur and not be detected in a timely manner. The Cash Receipts Policies and Procedures manual provides that cash collections should be deposited into the City s main depository bank account or with an approved City depository cashier within 24 hours after receipt. We noted that cash collections generated within various Police Units are taken to the Property Unit on a daily basis and secured in the Unit s vault. Upon receipt of said cash, the vault section of the Property Unit is required to prepare the cash collection for deposit into the City s bank account by the City s armored courier contractor. However, our review of bank deposits made in the months of April and May 2005, disclosed that cash collections were not processed and provided to the City s armored courier contractor within 24 hours after being signed for by the Vault Section of the Property Unit as shown below: 16

21 Range of No. of Range of Unit Deposits Deposits Days late Special Events $1,232 to $13, to 4 Records $ to $ to 5 Recommendation We recommend that the appropriate internal control procedures be implemented to address each of the deficiencies noted above. Auditee's Response and Action Plan The auditee concurred with the findings and recommendation. See written responses on pages 34 through

22 FINANCE DEPARTMENT LACK OF DOCUMENTATION OF SUPERVISORY VERIFICATION OF CASH REGISTER VOIDS. The Treasury Section of the Finance department processed and collected approximately $106 million in revenues through two cash registers located on the fourth floor of the Miami River Center (MRC) building during the audit period. During each day various types of fees were collected by each cashier. Our review of 39 cash register tapes for the month of November 2004 disclosed a total of 32 voids that resulted from wrong cash register ring-up of various sales transactions. The supervisory pre-approval of the voids/no-sales transactions that were processed as part of the tapes tested were not documented. The absence of supervisory review and documentation of such review increases the risk of irregularities and/or misappropriations. Subsequent to our observation and audit inquiry, supervisory review is now being documented. Recommendation None. Subsequent to our observation and audit inquiry, supervisory review is now being documented. Auditee's Response and Action Plan None. Subsequent to our observation and audit inquiry, supervisory review is now being documented. 18

23 PARKS AND RECREATION DEPARTMENT VIRGINIA KEY BEACH LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS. The Virginia Key Beach processed and collected approximately $54,000 in toll booth revenues during the audit period. A toll charge of $10 is waived and not assessed on Solid Waste, Miami-Dade Water and Sewer and similar trucks/vehicles seeking access to the Beach on a daily basis. Our review disclosed the following control deficiencies: We noted that a single cashier mans the toll booth and is responsible for granting all access to the Beach, including free access during each shift. Cashiers were not required to obtain and document information relating to vehicles that were granted free access and there is no electronic device at the toll booth entrance that could independently track the number and/or type of vehicles that gain access to the Beach. Under these conditions, there is increased risk of errors, irregularities and/or theft. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that when the custodian of a working fund is transferred to another employee, the employee releasing said funds should obtain a receipt for same, and the employee who received the funds should sign for the receipt. Said procedures require that the transfer be documented on a Transfer of Custodian Form and filed with the Finance department. However, our review disclosed that two employees who handled change funds were not the custodians of record. The Cash Receipts Policies and Procedures manual provides that cash collections should be deposited into the City s main depository bank account or with an approved City depository cashier within 24 hours after receipt. However, we noted that cash collections were deposited into the City s bank account on a weekly basis. For example, the cash receipt for July 18, 2004 totaling $712 was deposited into the City s bank account on July 27,

24 Recommendation We recommend that the appropriate internal control procedures be implemented to address each of the deficiencies noted above. Auditee's Response and Action Plan The auditee concurred with the findings and recommendation. See written responses on pages 43 through

25 CONFERENCES, CONVENTIONS, AND PUBLIC FACILITIES DEPARTMENT LACK OF ADEQUATE SAFEGUARDS FOR CASH COLLECTIONS. The Conferences, Conventions, and Public Facilities department is responsible for managing all City owned marinas (vessel docking facilities). As part of our audit we reviewed safeguards relative to cash collections at Miamirina at Bayside and Marine Stadium Marina. The Miamirina at Bayside processed and collected approximately $1.4 million in docking fees during the audit period and the Marine Stadium Marina processed and collected approximately $891,000 in docking fees during said audit period. Our review disclosed the following control deficiencies: MIAMIRINA AT BAYSIDE. Our review of the transactions log for the $50 change fund, disclosed 105 different days (May 6, 2005 through August 20, 2005) of shortages ranging from $6.47 to $ The change fund custodian was unable to provide any explanation and there was no evidence to indicate that this discrepancy was investigated and resolved by management. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that when the custodian of a working fund is transferred to another employee, the employee releasing said funds should obtain a receipt for same, and the employee who received the funds should sign for the receipt. Said procedures require that the transfer of the custody of petty cash from one employee to another be documented on a Transfer of Custodian Form and filed with the Finance department. However, our review disclosed that employees who handled the petty cash and change funds, in the amounts of $150 and $155 respectively, were not the custodians of record. 21

26 As first reported in audit report number , dated July 18, 2000, we again observed that dock attendants secure the fees collected in their individual pockets. Good business practice would dictate that automated cash register be used to process and secure cash sales transactions. An automated cash register would provide detailed accounting for all sales transactions; better cash inflow/outflow control; and monies collected would be better safeguarded against theft or being lost. When monies collected are secured in employee s pockets, there is an increased risk that errors, fraud, and/or irregularities could occur and not be detected in a timely manner. Upon audit inquiry, the Acting Director stated that the internal controls currently in place are sufficient to account for and monitor the small daily short-term dockage point of sale transactions collected by staff. She also noted that the physical layout of marina and staff constraints makes it impractical from a business standpoint to require either short term dockage customer or marina staff to travel the great distance required to process these payments. City s policies and procedures for working, petty cash and change funds provide that request for reimbursement of any expenditure from petty cash be made at least once each month. However, as of August 19, 2005 audit field work date; the petty cash fund disbursements totaling $54.68 for the months of June through August, 2005 were not submitted for reimbursement as required. MARINE STADIUM MARINA. A review of the transactions log for the $150 change fund, disclosed a shortage of $5.05. Also, a review of the transactions log for the $300 petty cash fund disclosed an overage of $3.35. The fund custodians were unable to provide any explanation and there was no evidence to indicate that said discrepancies were investigated and resolved by management. Upon review of the transactions and cash balance relative to a $300 petty cash fund, we observed an un-cashed reimbursement check for $ Said check has remained uncashed since September 28, 2001, although the fund had continuously been replenished since September 28, We also noted that the remaining cash balance available for 22

27 emergency needs totaled only $ Petty cash transactions log indicated that the fund had not been replenished since January 11, Please note that the City s policies and procedures for working, petty cash and change funds provides that request for reimbursement expenditures from petty cash be made at least once each month. The City s Working/Petty Cash/Change Fund Policies and Procedures, which provides guidance on how said funds could be used and/or safeguarded, requires that when the custodian of a working fund is transferred to another employee, the employee releasing said funds should obtain a receipt for same, and the employee who received the funds should sign for the receipt. Said procedures require that the transfer of the custody of petty cash from one employee to another be documented on a Transfer of Custodian Form and filed with the Finance department. However, our review disclosed that employees who handled the petty cash and change funds, in the amounts of $300 and $150 respectively, were not the custodians of record. Recommendation We recommend that the appropriate internal control procedures be implemented to address each of the deficiencies noted above. Auditee's Response and Action Plan As it relates to the dock attendants securing the fees collected in their individual pockets, the Acting Director stated that the internal controls currently in place are sufficient to account for and monitor the small daily short-term dockage point of sale transactions collected by staff. She also noted that the physical layout of marina and staff constraints makes it impractical from a business standpoint to require either short term dockage customer or marina staff to travel the great distance required to process these payments. 23

28 The Acting Director concurred with other audit findings and recommendation. See pages 45 and

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